Privacy Policy

This "Privacy Notice" describes the practices of ODT, Inc., a wholly owned subsidiary of CryptoFi, Inc. (hereinafter referred to as "ODT"), or hereinafter referred to as ("we," "us" or "our") in relation to the product and service offerings through On-Demand Trading. This Privacy Policy explains what Personally Identifiable Information (commonly referred to as "PII") we collect, why we collect it, how we use and disclose it, your choices, any rights you may have, and how you can contact us about our privacy practices. This Privacy Policy does not apply to third-party websites, products, or services, even if we provide links to those third parties or they provide links to us. The protection of your privacy is important to us; please take the time to know and understand our policies and practices. Feel free to print and keep a copy of this Privacy Policy; however, we reserve the right to change our policies and practices at any time. You will always find the latest version of this Privacy Policy on this page (https://www.ondemandtrading.com/privacy-policy).

Personal information typically means information that identifies or is reasonably capable of identifying an individual directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or reasonably identified individual. For the purposes of this Privacy Policy, only the definition of PII from the applicable law of your legal residence will apply to you and be deemed your "Personal Information." We collect personal information that you voluntarily provide to us when you register on the website, express an interest in obtaining information about us or our products and services when participating in activities on the website, or otherwise when you contact us. The personal information we collect depends on the context of your interactions with us and the On-Demand Trading service website (https://www.ondemandtrading.com/), the choices you make, and the products and features you use. The personal information we collect may include the following: • Identification Information – We collect name, address, phone number, email address, government-issued identification numbers (which may include Social Security Number or equivalent, driver's license number, passport number), usernames, passwords, contact preferences, contact or authentication data, salary information, occupation, government-issued identity documents, selfie photos, and other similar information. • Financial Information – such as bank statements, bank account information, and routing number; • Correspondence – information you provide to us in correspondence, including but not limited to account registration, account opening, trade requests, and customer support; • Sensory Information – images collected for identity identification and audio recordings; • Biometric Information – scans of face geometry extracted from identity documents; • Employment Information – job title, occupation, source of wealth or source of funds; • Institutional Information – for individuals utilizing business accounts for payments; we may collect additional information, including but not limited to beneficial ownership, business legal name, Employer Identification Number ("EIN") and proof of legal existence; • Online Identifiers – Internet Protocol (IP) address and/or browser and device characteristics; • Device and Usage Data – We automatically collect certain information when you visit, use, or navigate our websites; • Social Media Login Data – We may provide you with the option to register with us using your existing social media account details.

You may be required to provide a valid photo ID as well as a Selfie photo for 'Liveness' authentication. ODT may also utilize a trusted third-party verification service for ID & Facial Recognition for the sole purpose of fraud prevention. The Company complies with state laws regarding the retention and destruction of biometric identifiers and information. Illinois, Texas, and Washington residents are hereby notified that biometric identifiers and information may be collected at time of onboarding for the purpose of identity verification and fraud prevention.

We will not collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information without written notice to you. We also do not sell, lease, trade, or otherwise profit from your biometric identifier or information. While in our possession, we will not disclose, redisclose, or otherwise disseminate any biometric information; unless given express consent by you to disclose or redisclose; is required by State or federal law or municipal ordinance or is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction. ODT, Inc. warrants that it shall store, transmit, and protect from disclosure all biometric identifiers and information using the reasonable standard of care and in the same way the Company stores, transmits, and protects other confidential and sensitive information. Illinois Residents – Biometric identifiers or biometric information may be retained for a minimum of three (3) years following your last transaction or when the initial purpose for collecting or obtaining such identifiers or information has been satisfied or as required by law in accordance with the Biometric Information Privacy Act (BIPA). Texas Residents – Biometric information may be retained up to one year after account closure unless otherwise required by applicable law. Washington Residents – Biometric information is expressly used for security purposes and for the prevention of fraud. At the end of the above-referenced retention period, the biometric identifiers and information will be permanently destroyed as required. By agreeing to the Terms of Service, Illinois, Texas, and Washington residents are consenting to the capture and use of biometric identifiers and information for the sole purpose of customer identification and authentication. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Personal Information you share during the registration process may be retained, even if your registration is left incomplete and/or abandoned.

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you, such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

Like many businesses, we also collect information through cookies and similar technologies. For more information, please refer to our Cookie Policy posted on our websites.

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our websites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, to enter into or fulfill a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below: We use the information we collect or receive to: • Facilitate account creation and logon process • Post testimonials • Request feedback • Enable user-to-user communications • Manage user accounts • Send administrative information to you • Protect our Services • Enforce our terms, conditions, and policies • Respond to legal requests and prevent harm • Fulfill and manage your orders • Administer prize draws, promotions, and competitions • Deliver and facilitate delivery of services to the user • Respond to user inquiries/offer support to users • Send you marketing and promotional communications • Deliver targeted advertising to you

We only share and disclose your information with verified and approved third-party on an as needed basis. If we have processed your data based on your consent and you wish to revoke your consent, please contact us at support@ondemandtrading.com. We only share information with your consent, to comply with laws, to provide you with services, protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis: • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. • Legal Obligations: We may disclose your information where we are legally required to do so. • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or act regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

We use Google Maps for the purpose of providing better service. The On-Demand Trading website uses Google Maps APIs which is subject to Google's Terms of Service. You may find the Google Maps APIs Terms of Service here https://developers.google.com/terms. To find out more about Google's Privacy Policy, please refer to this link https://policies.google.com/privacy?hl=en-US. We use the Google Maps API to retrieve certain information when you make location-specific requests which include mailing addresses. We obtain and store on your device ('cache') your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Maps APIs we use to store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway), please review our Cookie Policy.

If you choose to register or log in to our services using a social media account, we may have access to certain information about you. Our websites may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). When and if you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the provider but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public on such social media platforms. We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant website. Please note that we do not control and are not responsible for other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

If you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Effective January 1, 2023, the California Privacy Rights Act ("CPRA") allows for more protections for California residents (consumers, employees, and contractors). The CPRA amends and extends the CCPA. As a California resident, you have the right to 'opt out' of not only selling but the sharing of your personal data. ODT does not sell or share your personal data with third parties unless to satisfy our service and commitments to you in the performance of our contract with you.

The Utah Consumer Privacy Act (UCPA) was enacted on March 24, 2022, and became effective December 31, 2023. Utah consumers are granted a range of new rights over the personal data that were previously provided to ODT Under the UCPA, consumers have the right to (1) know or confirm processing activity; (2) access their personal data; (3) obtain a copy of their personal data in a portable and readily usable format; (4) ability to request for deletion of their personal data; (5) opt out of targeted advertising and sales of their personal information; (6) right to avoid discrimination as a result of exercising their consumer rights under the UCPA. To exercise rights as described above; please contact us at support@ondemandtrading.com.

The Virginia Consumer Data Protection Act (VCDPA) effective January 1, 2023, provides Virginia consumers rights related to your personal data. Under the Act, these rights include (1) the right to know, access, and confirm personal data; (2) the right to request deletion of your personal data; (3) the right to correct inaccuracies of personal data; (4) the right to portability (obtain a copy of your personal data in a portable format); (5) the right to opt out of processing of personal data for targeted advertising purposes; (6) the right to opt out of sale of personal data; (7) the right to opt out of profiling based on personal data; (8) the right to not be discrimination against exercising consumer rights under the VCDPA. To exercise your rights described above, please contact us at support@ondemandtrading.com.

The Connecticut Data Privacy Act (CDPAC) and the Colorado Privacy Act (CPA), both effective July 1, 2023, provide residents the following rights: • The right to access personal data collected • The right to correct inaccuracies in personal data • The right to delete personal data • The right to obtain a copy of their personal data in a portable and readily usable format • The right to opt-out of (1) the sale of their personal data; (2) the processing of personal data for targeted advertising; (3) profiling • The right to designate an authorized agent If you are a resident of Connecticut or Colorado and wish to exercise your rights described above; please contact us at support@ondemandtrading.com.

We will update and revise this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions, privacy concerns or wish to exercise your rights referenced above, you may email us at support@ondemandtrading.com or by mail: Corporate Mailing Address ODT, Inc. Attn: Compliance 30 N Gould Street Suite 37749 Sheridan, WY 82801 888.526.2149 Opt. 2 compliance@ondemandtrading.com ODT, Inc. is a wholly owned subsidiary of InvestiFi, Inc., a Delaware-registered corporation.