Privacy Policy

Last updated: August 4, 2022

Vesta Equity Inc. (the “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, http://www.vestaequity.net, and other sites we own and operate.

This policy describes the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information we collect:

• On this Website.
• In email, text, and other electronic messages from you.
• When you interact with our advertising and applications on third-party websites and services.

It does not apply to information collected:

• Offline or through any other means, including on any other website operated by us or any third party; or
• By any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you disagree with our policies and procedures, you may choose not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to this Privacy Policy). Your continued use of this Website after we make changes is deemed to be an acceptance of those changes, so please check the policy periodically for updates.

1. DEFINITIONS

The terms used in this Privacy Policy have the meanings defined below. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

• Account means an individual account created for you to access our Service or parts of our Service.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
• Company (referred to as either the "Company,” "we,” "us," or "our" in this Agreement) refers to Vesta Equity Inc.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA but is physically outside the USA for a temporary or transitory purpose.
• Cookies are small files placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses.
• Data Controller, for the GDPR (General Data Protection Regulation), refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of processing Personal Data.
• Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual.
  For the purposes of GDPR, Personal Data means any information relating to you, such as a name, an identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, or economic, cultural or social identity.
  For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the services provided via the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by your use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to the website accessible from http://www.vestaequity.net and any subdomains thereof.
• You means the individual or other legal entity on behalf of which such individual is, accessing or using the Service, as applicable.

2. COLLECTION OF YOUR DATA

Personal Data

While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally Identifiable Information may include, but is not limited to:

• First name and last name
• Email address
• Date of birth
• Phone/mobile number
• Home/mailing address
• Digital asset wallet address
• Social security number
• Driver License’s Number
• Financial Information
• Other information necessary for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance purposes

We may collect personal information from you when you do any of the following on our Website:

• Register for an account
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you access our Service.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Website and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information and improve and analyze our Service. This allows us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return to our Website. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on your Device that enables the website to recognize the computer or user each time the user returns to the website. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may be unable to use some parts of our Service. You can learn more about cookies here: All About Cookies by TermsFeed.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a specific section and verifying system and server integrity).

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and avoid having to re-enter your preferences every time you use the Website.
• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the data collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features, or new functionality of the Website to see how our users react to them.
• Third-Party Use of Cookies and Other Tracking Technologies
  Some content or applications, including advertisements, on the Website, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide interest-based advertising or other targeted content. We do not control third parties' tracking technologies or how they may be used. You should contact the responsible provider directly if you have any questions about an advertisement or other targeted content.

3. PERSONAL DATA USE, COLLECTION, TRANSFER, AND RETENTION

The Company may use Personal Data for the following purposes:

• To provide you with Service by enabling you to access and use our Website, create an Account, manage your Account, and customize or personalize your experience of our Website.
• For the performance of a contract, including but not limited to facilitation with payment and transaction on the Website, and the development, compliance, and undertaking of the contract for the products, items, or services offered with the Service.
• To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
• For promotional purposes, we contact you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• To deliver targeted advertising to you: We may use your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and location and to measure its effectiveness.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or another sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by about our Service users is among the assets transferred.
• To protect you by detecting, preventing, or investigating security breaches, fraud, and other unauthorized or illegal activity.
• To enforce our Terms of Use.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and your experience.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to you after you visited our Service, to contact you.
• For business transactions: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies we control or are under common control with us.
• With employees and business partners: We may share your information with our employees, contractors, and related entities, with our existing or potential agents, and with our business partners who offer you certain products, services, or promotions.
• With other users: when you share personal information or otherwise interact in public areas, such information may be viewed by all users and publicly distributed outside.
• With courts, regulators, and law enforcement: We may disclose your information to courts, tribunals, and regulatory authorities, in the event you fail to pay for services we have provided to you and to courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights.
• With your consent: We may disclose your personal information for any other purpose.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take steps reasonably necessary to ensure that your data is treated securely under this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Control of Your Personal Data

• Your choice: By providing personal information to us, you understand that we will collect, hold, use, and disclose your personal information by this privacy policy. You may choose to reject cookies and certain other tracking technologies by changing the setting of your browser. You do not have to provide personal information to us; however, if you do not, it may affect your use of our platform or the products and services offered on or through it.
• Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
• Marketing permission: If you have previously agreed to use your personal information for direct marketing purposes, you may change your mind by opting out of the promotional communications or contacting using the details below. Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once per year about sharing their Personal Data with third parties for their direct marketing purposes.
• Access: you may request details of the personal information that we hold about you.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
• Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example, providing user support), we will not deny you goods or services and charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
• Notification of data breaches: We will comply with laws applicable to you regarding any data breach.
• Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please get in touch with us using the details below and provide full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority about your complaint.
• Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help you confirm your identity.

Security of Your Personal Data

When we collect and process personal information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure. No one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your information within the bounds of our services. For example, you are responsible for ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

Processing Your Personal Data

The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process, and transfer information about your activity on our Service in accordance with their respective privacy policies.

We may use third-party service providers to track, analyze and collect web traffic, contact you through email marketing, collect your digital identification, KYC (Know Your Customer) and AML (Anti-Money Laundering) information, and confirm your accreditation status; execute and notarize contracts, and access property records originating from the public domain or Multiple Listing Service (this data may also be used in closing or title services, including but not limited to property closing, title searches, notary services, and recording services).

Behavioral Remarketing

The Company uses remarketing services to advertise to you after you access or visit our Website. Our third-party vendors and we use cookies and non-cookie technologies to help recognize your Device and understand how you use our Service so that we can improve our Service to reflect your interests and serve you advertisements that are likely to be of more interest to you.

These third-party vendors collect, store, use, process, and transfer information about your activity on our Service under their Privacy Policies and to:

• Measure and analyze traffic and browsing activity on our Service
• Show advertisements for our products and services to you on third-party websites or apps
• Measure and analyze the performance of our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information to serve you interest-based advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt out of all personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your mobile device's Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Service with these third-party vendors. This allows our third-party vendors to recognize and deliver ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the Privacy Policy of each vendor listed below.

4. CHILDREN’S PRIVACY

Individuals under the age of 13 are not permitted to use our Website or Services. We do not knowingly collect personally identifiable information from anyone under the age of 13. Please contact us if you are a parent or guardian and know that your child has been provided with Personal Data. If we learn we collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

California Privacy Rights for Minor Users

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain the removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact using the contact information provided below and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

5. GENERAL DATA PROTECTION REGULATION (GDPR)

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary to protect your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task carried out in the public interest or the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the legitimate interests pursued by the Company.

In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Your Rights under the GDPR

You have the right under this Privacy Policy, and by law, if you are within the EU, to:

• Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you cannot perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your Personal Data. This right exists where we rely on legitimate interest as the legal basis for our processing, and there is something about your particular situation which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object to where we are processing your Personal Data for direct marketing purposes.
• Request erasure of your Personal Data. You have the right to ask to delete or remove Personal Data when there is no good reason to continue processing it.
• Request the transfer of your Personal Data. We will provide you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information you initially provided consent to or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent from using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

6. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

This privacy notice section for California residents supplements the information contained in our Privacy Policy, and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information that we may have collected from California residents within the last twelve (12) months. Please note that the types and examples provided in the list below are those defined in the CCPA. This does not mean that we collected all examples of that category of personal information but reflects our good faith belief that some of that information from the relevant category may be and may have been collected. For example, specific categories of personal information would only be collected if you provided such personal information directly to us.

Under the CCPA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service.
• Indirectly from you. For example, from observing your activity on our Service.
• Automatically from you. For example, through cookies, we or our Service Providers set on your Device as you navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze our Service, third-party vendors to deliver targeted advertising to you, or other third-party vendors that we use to provide the Service.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide you with our Service.
• To provide you with support and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our Service.
• To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise outlined in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, prosecuting those responsible for such actions.

Please note that the examples provided above are illustrative and not intended to be exhaustive. Please refer to the "Use of Your Personal Data" section for more details on how we use this information.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.

Disclosure and Sale of Personal Information for Business Purposes or Commercial Purposes

As defined in the CCPA, "sell" and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means we may have received some kind of benefit for sharing personal information, but not necessarily a monetary benefit.

We may use, disclose, or sell and may have used, disclosed, or sold in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were disclosed.

When we disclose personal information for a business or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.

Sharing Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Our affiliates
• Our business partners
• Third-party vendors to whom you or your agents authorize to disclose your personal information in connection with our products or services.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes, and share of personal information.
• The right to say no to the sale of Personal Data (opt-out). You have the right to direct us not to sell your personal information. To submit an opt-out request, please get in touch with us.
• The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records unless an exception applies. We may deny your deletion request if retaining the data is necessary for our Service Providers.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising your consumer rights.

Exercising Your CCPA Data Protection Rights

To exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by email.

Only you, or a person registered with the California Secretary of State you authorize to act on your behalf, may make a verifiable request related to your personal information. Your request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
• Please describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly.

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you.

We will disclose and deliver the required information within 45 days of receiving your verifiable request. The period to provide the required information may be extended by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12 months preceding the verifiable request’s receipt.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

“Do Not Track” Requests

As California Online Privacy Protection Act (CalOPPA) requires, we disclose that our Service does not respond to Do Not Track signals. Some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting your web browser's preferences or settings page.

7. YOUR STATE PRIVACY RIGHTS

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, considering its nature and processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request by emailing us.

Please email us to exercise any of these rights or appeal a decision regarding a consumer rights request.

8. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that we do not operate. You will be directed to that third party's site if you click on a third-party link. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will inform you via email and a prominent notice on our website before the change becomes effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. CONTACT US

If you have questions about this Privacy Policy, contact us at privacy@vestaequity.net.