This Privacy Policy (the “Policy”) explains how Portmoto Ltd. (“We” or “Us”) collects, stores, uses, and discloses personal information (“Information”) from our users (“You”) in connection with the website located at https://portmoto.com (the “Site”).

Please read and make sure You understand this Policy. We may modify this Policy in the future, so please check back regularly for updates. We reserve the right to make revisions at any time and the revisions will be effective upon our posting updates to this website. If You access the Site after a revision is posted, Your use will constitute acceptance of the revision.

INFORMATION COLLECTED

This Policy applies to Information We collect from You, but does not apply to any services or products offered by third parties and made available to You through our Site. We obtain Information in the following forms: (i) Information provided by You as part of registration (ii) Information that is obtained from Your use of the Site.

(i) Information provided by You: You may be required to register in order to access certain features of the Site. To become a registered user You will be asked to create a personal account, which may include Your name, login name and password, email address, and payment information.

(ii) Information from Your Use of the Site: We may automatically collect certain Information from Your use of the Site, such as usage data, preferences, or any other data that includes Information concerning how You use the Site. In particular, We may collect the following types of Information:

• Your browser type, language, plug-ins, Internet domain and operating system; Your Internet Protocol (IP) address;
• The website(s) You visited before visiting the Site and the website(s) You visited after visiting the Site;
• Unique identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
• Data collected through cookies and other tracking technologies; and
• Data related to Your interactions with content on the Site, such as the type of content viewed or favorited in the Site.

USE OF COLLECTED INFORMATION

We use Information collected from your use of the Site specifically to: (i) analyze, operate and improve the Site and services offered thereon; (ii) customize the content You see when You use the Site; (iii) enforce this Agreement; (iv) conduct market analysis, traffic flow analysis and related reporting to third parties; and (v) for any other purposes disclosed to You at the time We collect Your Information.

We may share certain Information with third party vendors who supply software applications, web hosting and other technologies for the Site. We will only provide these third parties with access to Information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such Information for any other purpose except to provide services in connection with the Site.

We will not share or sell any of Your Information to any third party except as otherwise stated in this Policy and in the following circumstances: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of the Site, or to protect any user's security or the security of other persons, consistent with applicable laws; (c) when disclosure is directed or consented to by the user who has input the Information; (d) in the event that We go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, Your Information will, in most instances, be part of the assets transferred; or (e) in limited circumstances, We may disclose Your email address in order to comply with laws and regulations, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act of 2003).

Please note that We may retain certain Information after Your account has been terminated. We reserve the right to use Your Information in any aggregated data collection after You have terminated Your Account, however We will ensure that the use of such Information will not identify You personally.

SECURITY OF INFORMATION COLLECTED

Information provided by You is protected by the login, email, and password You create when registering to use the Site. Please understand that You can help prevent the unauthorized disclosure of Information by choosing and protecting Your login, email, and password appropriately. You can also help prevent unauthorized disclosure by not sharing your login, email, and password and preventing others from using Your computer or mobile device.

We use commercially reasonable procedures to protect all collected Information. Please understand that no security system is perfect and, as such, We do not guarantee the security of the Site, or that Your Information won't be intercepted while being transmitted to Us. If We learn of a security systems breach, then it may either post a notice, or attempt to notify You by email and will take reasonable steps to remedy the breach.

Although the Site may contain links to third party websites, We are not responsible for the privacy policies and/or practices on those third party websites. Where We have linked to a third party website You should read the privacy policy stated on that third party website.

QUESTIONS

If You have any questions concerning this Policy or the Site, please contact us at support@portmoto.com

CALIFORNIA PRIVACY RIGHTS NOTICE

In addition to the rights provided for in the Privacy Policy above, if you are a California resident, you have additional rights as set forth in this California Privacy Rights Notice. The California Consumer Privacy Act of 2018 (“CCPA”) provides you with the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. To the extent we share your personal information in this way, you may receive the following information:

• the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and
• the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Pursuant to the CCPA, California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights Notice section.

• For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information.
• We will not discriminate against those who exercise their rights.
• We do not sell or share your personal information to third parties. Notwithstanding the foregoing, under the CCPA, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information.

You can exercise your rights by adjusting the settings in your account, or by contacting us with the information provided in the Privacy Policy.

If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

Last Updated: September 18, 2022