Privacy Policy

1. Information We Collect

We may collect the following categories of information:

A) Information you provide

• Identifiers and contact details (e.g., legal name, email, phone)
• Billing address
• Account access information (e.g., password or authentication tokens)
• Onboarding and profile responses (e.g., preferences, time horizon, risk tolerance)
• Communications you send us (support requests, emails, messages)
• Payment-related information (e.g., confirmation of ACH/wire transfers, transaction references, and proof of payment uploads)

Note: We generally avoid collecting full bank account and routing numbers unless necessary. When required, we recommend using secure, tokenized methods and trusted providers rather than storing sensitive bank details in our systems.

B) Information collected automatically

• Device and usage data (e.g., IP address, browser type, pages viewed, timestamps, referring URLs)
• Cookies and similar technologies (see “Cookies and Analytics” below)

C) Information from third parties (if applicable)

• Service providers (e.g., hosting, analytics, email/SMS platforms)
• Identity verification/KYC providers (if enabled in the future)
• Payment processors (if enabled in the future)

2. How We Use Information

We may use personal information to:

• Provide and operate the Services (account access, portal functionality, user support)
• Communicate with you (service announcements, portal notifications, status updates you opt into)
• Improve and secure the Services (fraud prevention, monitoring, debugging, and system integrity)
• Comply with legal obligations and enforce our Terms
• Perform analytics and understand usage trends

3. How We Share Information

We may share information:

• With service providers who help us operate the Services (e.g., hosting, analytics, communications)
• For legal compliance (e.g., subpoenas, court orders, lawful requests)
• In connection with a business transfer (e.g., merger, acquisition, financing, reorganization, or asset sale)
• With your consent or at your direction

We do not publicly post your personal information.

4. Cookies and Analytics

We may use cookies and similar technologies to:

• Keep you logged in (if applicable)
• Remember preferences
• Analyze traffic and performance

You can control cookies through your browser settings. Some features may not function properly if cookies are disabled.

5. Data Retention

We retain personal information as long as reasonably necessary to:

• Provide the Services
• Maintain records for legitimate business purposes
• Comply with legal obligations
• Resolve disputes and enforce agreements

6. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

7. Your Choices

Depending on your settings and features available in the portal, you may be able to:

• Update certain account information in the portal
• Opt out of non-essential communications (e.g., marketing, if applicable)
• Control cookies through your browser settings

8. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have rights such as:

• The right to know/access the personal information we collect and how we use it
• The right to delete personal information (subject to exceptions)
• The right to correct inaccurate personal information
• The right to opt out of “sale” or “sharing” of personal information (if applicable)
• The right to limit the use/disclosure of sensitive personal information (if applicable)
• The right to non-discrimination for exercising your rights

A) Notice at Collection (California)

At or before collecting personal information, we provide a notice describing:

• The categories of personal information collected, and
• The purposes for which they are used.

B) How to Submit a Request

You (or an authorized agent) may submit a request by:

• Email: contact@privatedeal.club

We will verify your request using information associated with your account and may request additional details for verification.

C) “Do Not Sell or Share”

We do not sell personal information as that term is commonly understood. If our practices change and we engage in “sale” or “sharing” as defined by California law, we will provide a “Do Not Sell or Share My Personal Information” mechanism.

9. Children’s Privacy

The Services are not intended for children under 16, and we do not knowingly collect personal information from children under 16.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date will reflect changes. Continued use of the Services after changes means you accept the updated Privacy Policy.

11. Financial Disclaimer

We do not guarantee returns, all values are estimates and may vary.

12. Contact

Cygnus IT Services LLC
Email: contact@privatedeal.club