Last Updated: July 31, 2022
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Portal Labs, Inc. (“Portal,” “we,” “us,” or “our”)provides an Application Programming Interfaces (API) and infrastructure forfinancial entities such as exchanges, fintechs, and financial institutions (the“Services”). This Privacy Policy describes how we handle personal informationthat we collect about our customers, including when they use our Services orvisit our website, www.portalhq.io.We treat all personal information covered bythis Privacy Policy as pertaining to individuals acting as businessrepresentatives, and not in their individual or household capacity. ThisPrivacy Policy does not apply to our handling of personal information that weprocess on behalf of our customers as a service provider.

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‍Personal Information We Collect

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‍Information you provide to us may include: 

• Accountinformation and contact details, such as your company’s name, your first andlast name, username and password, email address, and phone number. 
• Communicationsthat we exchange with you, including when you contact us with questions,feedback, or otherwise.
• Marketing data,such as your preferences for receiving our marketing communications, anddetails about your engagement with them.
• Other data notspecifically listed here, which we will use as described in this Privacy Policyor as otherwise disclosed at the time of collection.

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Thirdparty sources. 

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‍We may combine personal information we receive from you withpersonal information we obtain from other sources, such as:

• Third parties,such as our business partners and others.
• Public sources,such as social media platforms.
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‍Automaticdata collection.

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We, our service providers, and our advertisingpartners may automatically log information about you, your computer or mobiledevice, and your interaction over time with our website and the Services (inyour capacity as our customer’s authorized user), our communications and otheronline services, such as:

• Device data, suchas your computer’s or mobile device’s operating system type and version,manufacturer and model, browser type, screen resolution, RAM and disk size, CPUusage, device type (e.g., phone, tablet), IP address, unique identifiers(including identifiers used for advertising purposes), language settings,mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), andgeneral location information such as city, state or geographic area.
• Online activitydata, such as pages or screens you viewed, how long you spent on a page orscreen, the website you visited before browsing to the website, navigationpaths between pages or screens, information about your activity on a page orscreen, access times, and duration of access, and whether you have opened ourmarketing emails or clicked links within them.We use the following tools forautomatic data collection:• Cookies, which are text files that websites storeon a visitor‘s device to uniquely identify the visitor’s browser or to storeinformation or settings in the browser for the purpose of helping you navigatebetween pages efficiently, remembering your preferences, enablingfunctionality, helping us understand user activity and patterns, andfacilitating online advertising.
• Local storagetechnologies, like HTML5, that provide cookie-equivalent functionality but canstore larger amounts of data, including on your device outside of your browserin connection with specific applications.• Web beacons, also known as pixeltags or clear GIFs, which are used to demonstrate that a webpage or email wasaccessed or opened, or that certain content was viewed or clicked.

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How We UsePersonal Information

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‍We use your personal information for the followingpurposes:

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To operate our Services:  

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• Provide, operate,maintain, secure and improve our Services.
• Fulfill a paymentor transaction initiated by you.
• Provideinformation about our Services.
• Communicate withyou about our Services, including by sending you announcements, updates,security alerts, and support and administrative messages.  
• Understand yourneeds and interests, and personalize your experience with our Services and ourcommunications.
• Respond to your requests, questions and feedback.

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‍Research and development. 

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‍As part of these activities, we may create aggregated,de-identified or other anonymous data from personal information we collect. Wemay use this anonymous data and share it with third parties for our lawfulbusiness purposes, including to analyze and improve the Services, and promoteour business.

Marketingand advertising, including for:

• Direct marketing.We may send you direct marketing communications as permitted by law, including,but not limited to, notifying you of special promotions, offers and events viapostal mail, email, telephone, text message, and other means. You may opt outof our marketing communications as described in the “Opt out of marketingcommunications” section below.
• Interest-basedadvertising. We engage our advertising partners, including third partyadvertising companies and social media companies, to advertise our Services andother services across the web. We and our advertising partners may use cookiesand similar technologies to collect information about your interaction(including the data described in the “Automatic data collection” section above)over time across the web, our communications and other online services, and usethat information to serve online ads. You can learn more about your choices forlimiting interest-based advertising in the “Online tracking opt out” sectionbelow.

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Complianceand protection, including to:

• Comply withapplicable laws, lawful requests, and legal process, such as to respond tosubpoenas or requests from government authorities.   •   Protect our, youror others’ rights, privacy, safety or property (including by making anddefending legal claims).
• Audit our internalprocesses for compliance with legal and contractual requirements and internalpolicies.
• Enforce the terms and conditions that govern our website andServices.
• Prevent, identify,investigate and deter fraudulent, harmful, unauthorized, unethical or illegalactivity, including cyberattacks and identity theft.

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How WeShare Personal Information

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‍We may share your personal information with:

• ‍Affiliates. Our corporate parent, subsidiaries, and affiliates, forpurposes consistent with this Privacy Policy.Service providers. Companies and individuals thatprovide services on our behalf or help us operate our Services or our business(such as banking partners, hosting, information technology, customer support,email delivery, and website analytics services). 
• Advertising partners. Third party advertising companies, including for theinterest-based advertising purposes described above, that may collectinformation on our website through cookies and other automated technologies.
• ‍Professional advisors. Professional advisors, such as lawyers, auditors, bankers andinsurers, where necessary in the course of the professional services that theyrender to us.
• ‍Authorities and others. Law enforcement, government authorities, and private parties,as we believe in good faith to be necessary or appropriate for the complianceand protection purposes described above.‍
• Business transferees. Acquirers and other relevant participants in businesstransactions (or negotiations for such transactions) involving a corporatedivestiture, merger, consolidation, acquisition, reorganization, sale or otherdisposition of all or any portion of the business or assets of, or equityinterests in, Portal or our affiliates (including, in connection with abankruptcy or similar proceedings).

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‍YourChoices

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Opt out of marketingcommunications. You may opt out of marketing-related communications byfollowing the opt out or unsubscribe instructions contained in the marketingcommunications we send you.

Online tracking opt-out. There are a number of ways to limit onlinetracking, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, includingcookies used for interest-based advertising. To do this, follow the instructionsin your browser settings. Many browsers accept cookies by default until youchange your settings. For more information about cookies, including how to seewhat cookies have been set on your device and how to manage and delete them,visit www.allaboutcookies.org.

• Blocking advertising IDuse in your mobile settings. Your mobile device settings may providefunctionality to limit use of the advertising ID associated with your mobiledevice for interest-based advertising purposes.
• Using privacy plug-insor browsers. You can block our websites from setting cookies used forinterest-based ads by using a browser with privacy features, like Brave, orinstalling browser plugins like Privacy Badger, Ghostery, or uBlock Origin, andconfiguring them to block third party cookies/trackers. You can also opt out ofGoogle Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.  
• Platform opt outs. Thefollowing advertising partners offer opt out features that let you opt out ofuse of your information for interest-based advertising:   
  • Google: www.adsettings.google.com
  • Facebook: www.facebook.com/about/ads  
  • Twitter: www.twitter.com/settings/personalization  
• Advertising industry optout tools. You can also use these opt out options to limit use of yourinformation for interest-based advertising by participating companies:  
  • Digital Advertising Alliance for Websites: outout.aboutads.info
  • Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices
  • Network Advertising Initiative: optout.networkadvertising.org
  Note that because these opt out mechanisms arespecific to the device or browser on which they are exercised, you will need toopt out on every browser and device that you use.

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Do Not Track.

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Some Internet browsers may be configured to send“Do Not Track” signals to the online services that you visit. We currently donot respond to "Do Not Track" or similar signals. To find out moreabout "Do Not Track," please visit http://www.allaboutdnt.com.

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‍Other Sites and Services‍

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‍Our Services may contain links to websites andother online services operated by third parties. In addition, our content maybe integrated into web pages or other online services that are not associatedwith us. These links and integrations are not an endorsement of, orrepresentation that we are affiliated with, any third party. We do not controlwebsites or online services operated by third parties, and we are notresponsible for their actions.

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‍DataSecurity

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We employ a number of technical, organizationaland physical safeguards designed to protect the personal information wecollect. However, no security measures are failsafe and we cannot guarantee thesecurity of your personal information.

‍Children

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‍The Services are not intended for use by childrenunder 13 years of age. If we learn that we have collected personal informationthrough our Services from a child under 13 without the consent of the child’sparent or guardian as required by law, we will delete it.

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‍Changes to This Privacy Policy

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‍We reserve the right to modify this Privacy Policyat any time. If we make material changes to this Privacy Policy, we will notifyyou by updating the date of this Privacy Policy and posting it on the website.

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‍How to Contact Us

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You can reach us by email at partner@portalhq.ioat the following mailing address:
Portal Labs, Inc.548 Market Street PMB 25754San Francisco, CA 94102