Republic Advisory Services Privacy Policy

This privacy policy (“Privacy Policy”) describes how Republic Crypto LLC dba Republic Advisory Services (“Republic Advisory Services,” “RAS,” “we,” “us,” or “our”), collects, uses and discloses any personal information you provide to us when using the services offered by RAS (the “Services”) on and through https://advisory.republic.com (the “Site”).

The Site is owned by OpenDeal Inc., Republic Advisory Services’ parent company. By accessing the Site or using the Services, you acknowledge and consent to our practices described below. Your access to the Site, use of the Services, this Privacy Policy and all defined terms used herein, are subject to and governed by our Terms of Service.

We emphatically value the trust of our users. We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy to learn about choices available to you regarding our use of your information.

Information We Collect

We collect your personal information in order to provide and continually improve our Services.

Here are the types of personal information we collect:

• Information You Give Us: We receive and store any information you provide in relation to the Services. This includes information that may personally identify you (“Personal Information”), such as your email address, name, phone number, birthday, address, gender, social security number (or equivalent for entities and those outside of the United States), investment experience, and your educational or employment history. This information may be collected when you register with us or one of our clients, qualify to participate in our clients’ offerings, or provide us with access to your accounts on third-party sites (“Third-Party Sites”). You can choose not to provide certain information, but then you might not be able to take advantage of many of our Services.
• Automatic Information: We automatically collect and store certain types of information about your use of the Services, including information about your interactions with the Site, such as IP (internet protocol) address, ISP (internet service provider), the web browser used to visit the Site, the time the Site is visited, which web pages were visited on the Site, a mobile device-type identifier, and other anonymous Site usage data. This data may allow us to determine more specific information about you, such as the operating system of the device used to access the Site and your approximate location. We also use third-party analytics services to provide us with a clearer picture of how you use the Site, such as where you click on the Site, non-sensitive text entered into the Site, and mouse movements.
• Cookies and Other Identifiers: We use technologies like cookies and web beacons to provide, improve, protect, and promote our Services. A cookie is a small text file containing a string of alphanumeric characters that may uniquely identify your browser that lets us help you log in faster and enhance your navigation through the Site. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), and allow us to track your usage of the Services over time. You can set your browser to not accept cookies, but this may limit your ability to use the Services. Similarly, we employ web beacons to anonymously track your usage patterns on the Site, or place clear gifs in HTML-based emails we send you to track which emails are opened and which links you click. This information allows for more accurate reporting and improvement of the Services. Although we do our best to honor your privacy preferences, we are not able to respond to “Do Not Track” signals from your browser or device at this time.
• Third-Party Sites: The Personal Information collected from the Third-Party Sites may be used to register you on our Site and to provide some of our Services. You may be able to revoke our access to your account on the Third-Party Sites by updating the appropriate settings in the account preferences of the respective Third-Party Sites. You understand that certain features of our Site may not be available to you if you choose to remove our access to your account with the Third-Party Sites.

How We Use Your Information

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use your information for the following purposes:

• To deliver and improve our Services.
• To manage your account and provide you with customer support.
• To perform research and analysis about your use of the Services.
• To develop, display, and track content and advertising tailored to your interests on the Services and other sites, including providing our advertisements to you when you visit other sites or mobile applications.
• To diagnose or fix technology problems.
• To automatically update the Site.
• To verify your identity and prevent fraud or other unauthorized or illegal activity.
• To enforce or exercise any rights in our Terms of Service.
• To provide users with statistics on how they use the Site relative to other anonymous users.
• To perform functions or services as otherwise described to you at the time of collection.

How We Share Your Information

We will share your information with our parent company, OpenDeal Inc., and its subsidiaries (our “Affiliated Entities”). If the Services you use are exclusively provided by RAS, you have the right to opt-out marketing communications from our Affiliated Entities (“Affiliate Marketing”), please see Your Choice About Your Information below for details.

Additionally, we provide your Personal Information on a confidential basis to non-affiliated companies we engage as vendors or agents to (i) facilitate the Services provided on the Site, such as counsels, advisors, accountants, and financial service providers, and (ii) to service our operation, such as maintaining software or servers, designing or implementing marketing initiatives on our behalf, or conducting audit or testing of any aspect of our operation or Services. Information will be shared with such parties only to the extent reasonably necessary for them to perform services for us or on our behalf and pursuant to confidentiality obligations, or in response to information requests, subpoenas, court orders, or legal process, from law enforcement agencies, self-regulatory organizations, state, federal and foreign regulators.

RAS does not sell any user data to third-party firms.

Your Choices About Your Information

If your Personal Information changes, or if you no longer want access to the Services, you may correct, update, amend, delete or request deletion by logging into your account, emailing us at [email protected] or by contacting us at the contact information listed at the bottom of this Privacy Policy. We will respond to your request within a commercially reasonable time.

When you sign up for our Services, we will send periodic emails to you regarding the Services or to tell you about additional services we believe will be of interest to you. You may choose to stop receiving our marketing emails or Affiliated Marketing emails by following the unsubscribe instructions included in these emails, adjusting your account notification settings, or contacting us at [email protected].

Data Retention

We will retain your Personal Information for as long as our relationship with you is active or as needed to provide you with the Services, unless a longer retention period is required by law. We may retain all of the Personal Information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligation, or where we otherwise reasonably believe that we have a legitimate reason to do so. If you wish to request that we no longer use your Personal Information, or if you have any questions about our data retention obligations and practices, please contact us at [email protected].

Security and Storage of Your Information

We use commercially reasonable efforts to follow generally accepted standards to protect Personal Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as bank account information) on our Site, we encrypt the transmission of that information using secure socket layer technology (SSL). From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is free of risk. Therefore, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards. We disclaim all responsibility and liability for unauthorized access to our servers and systems.

The Services are maintained in the United States of America. Although we welcome users from all over the world, by accessing the Services, you consent to and authorize the export of Personal Information to the United States and its storage and use as specified in this Privacy Policy. Please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. By using the Service you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. Note the laws of the United States might not be as comprehensive or protective as the laws in the country where you live.

Children’s Privacy Policy

The Site is not intended for use by children. No one under eighteen (18) years of age is allowed to use the Site, the Services, provide any Personal Information or receive our email distributions. We do not knowingly solicit or collect Personal Information from anyone under eighteen (18) years of age. If you believe that a minor has disclosed Personal Information to RAS, please report this to us immediately at [email protected].

Your California Privacy Rights

If you are a California resident, the processing of your Personal Information is subject to the California Consumer Privacy Act (“CCPA”) and you have certain rights with respect to that information. In particular, you have a right to request that we provide you with the following information:

• The categories and specific pieces of Personal Information we have collected about you.
• The categories of sources from which we collect Personal Information.
• The purposes for collecting, using, or selling Personal Information
• The categories of third parties with which we share Personal Information.
• The categories of Personal Information disclosed about you for a business purpose.
• The categories of Personal Information sold about you and the categories of third parties to which the Personal Information was sold, by category or categories of Personal Information for each third party to which the Personal Information was sold.

RAS does not sell any user data to third-party firms. To request any of the information listed above, please contact us at [email protected] or at the address below.

Republic Advisory Services
Legal Department
Three Embarcadero Center
Suite P5
San Francisco, California 94111

You also have a right to request that we delete your Personal Information under certain circumstances, subject to several exceptions. Finally, you have a right not to be discriminated against for exercising rights set out in the CCPA.

Changes of Control

In the event RAS or the Affiliated Entities merge with another entity, is sold, or transfers its assets, we may disclose or transfer your Personal Information in connection with the negotiation and/or conclusion of such transaction.

Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of this Site following the posting of any changes to this Privacy Policy means you consent to such changes. The “Effective Date” at the bottom of this page indicates when this Policy was last revised.

Opt Out of Certain Cookies Tracking:

The Site uses tools to facilitate the collection of information. For example, the Site uses Google Analytics, if you wish to disable Google Analytics from all websites you visit (not limited to this Site), you can follow this link. You can read the other relevant privacy policies here, here, here and here. Please contact us if you wish to opt out of any of the tools we use. Please note, we reserve the right to add more tools or disable tools and will update this Privacy Policy to reflect these changes. Your request to disable or your disabling of tools may limit your ability to access and utilize the Site.

This site is protected by reCAPTCHA and Google’s privacy policy and their terms of service apply.

How to Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at [email protected].

Effective Date

The Effective Date of this Privacy Policy is Jul 29, 2020.