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In order to ensure transparency and give you more control over your Personal Information, this privacy policy (“Privacy Policy”) governs how we, Tres Finance, Inc., company located at 7 World Trade Center, 250 Greenwich St #7, New York, NY 10007 (“Tres Finance”, “we”, “our” or “us”) use, collect and store Personal Information that we collect or receive from or about you (“you”) in connection with https://www.tresdevmike.wpenginepowered.com/ and the services provided (the “Services”):We greatly respect your privacy, which is why we make every effort to provide a platform that lives up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement. Tres Finance provides a data management platform that aggregates crypto data across different wallets, accounts and platforms so that crypto entities and financial teams can better understand their businesses. Tres’ financial platform provides an unparalleled level of visibility, monitoring, alerting and automation to Web3 finance teams and seamlessly translates high volumes of raw blockchain data into actionable information. 
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.
This Privacy Policy forms part of our Terms of Use which is available at https://www.tresdevmike.wpenginepowered.com/terms-of-use. Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

1. What information we collect, why we collect it and how we use it

(i) We Process the Following Personal Information: 
  1. Information You Provide Directly to Us. In connection with accessing our Services, we may collect information from you, which can be used to identify you (“Personal Information”), such as your name, shipping/billing address, email address, phone, username and password. We collect information when you register or open an account, sign in, pay a bill, purchase a Service, use a Service, call us for support, or give us feedback.
  2. Information from Other Sources. Tres Finance may also obtain information about you from other sources, including publicly or commercially available information, and through third-party data platforms, partners and service providers such as when you sync a third party account or service with your Tres Finance Service. 
  3. Automatic Data Collection. We may automatically collect certain information through your use of the Tres Finance Services, such as your Internet protocol (IP) address, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Tres Finance Services. For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. Our Services may change over time and we may introduce new features that may collect new or different types of information.
(ii) We process information for the following purposes:
  1. To provide you with the Services. Tres Finance will use your information to provide the Tres Finance Services. 
  2. For Administrative Purposes. Tres Finance may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with the Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer the Tres Finance Services.
  3. To Market the Services. Tres Finance may use information to market the Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in the Services; (v) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.
  4. Security purposes. Some of the above mentioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. 
  5. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve the Services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
  6. Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Services. If you would like to opt out of the Technologies we employ on the Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

2. How we protect and retain your personal information

  1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information, including by encrypting and anonymizing your information; undergoing periodic security audits to ensure high levels of security; training our staff and requiring them to safeguard your data; and following cloud storage best practices (including the AWS Foundational Security Best Practices Standard and the CIS Benchmarks program). However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your information. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Tres Finance’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud. 

3. How we share your personal information

In addition to the recipients described above, we may share your information as follows: 

  1. The information Tres Finance gathers is shared with our partners and other third parties. 
  2. We may also share information with our affiliated companies about you. 
  3. We may use third party service providers to process your information for the purposes outlined above, including, without limitation:
    3.3.1 With cloud service providers for hosting purposes;
    3.3.2 With websites and web content creation platforms in order to help us manage our Website;
    3.3.3 With email providers, marketing, CRM, other similar tool providers; and 
    3.3.4 With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
  4. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Tres Finance, our Services, customers, employees, property, and the public.
  5. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
  6. Where you have otherwise provided your consent to us for sharing or transferring your information.

4. Your privacy rights

  1. Rights: You can exercise your rights by contacting us at privacy@tres.finance. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.  
  2. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to privacy@tres.finance. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.  

5. Use by children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@tres.finance

6. Interaction with third-party products

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. Analytic tools/cookies

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
  • Mixpanel. We collect information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/. 
  • Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.  For further details, please see the ‘about Hotjar’ section of Hotjar’s support site. 
  • FullStory. If you are a visitor of our Website, FullStory collects information on your use of the Website, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol address. FullStory uses publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. The purpose in collecting your usage data is to better understand how you use our Website. FullStory’s privacy policy is available here: https://www.fullstory.com/legal/privacy-policy/.
  • Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above. 
  • YouTube API. Our website and platform uses YouTube API to collect and process the captions of YouTube’s videos, as requested by you. We do not intend to collect or share any Personal Data with YouTube via the API. For further details please see the YouTube’s Terms of Service at https://www.youtube.com/t/terms and the Google privacy policy at http://www.google.com/policies/privacy.
  • Through the Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you.  
  • We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

8. Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@tres.finance.***

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