Portwars Privacy Policy 

Last Updated: 10/2/2024 

Portwars.com, (collectively “Portwars,” “we,” “us,” or “our”) is a media platform providing live and on-demand interactive video programming and chat forums about topics including but not limited to financial markets, trading, sports, entertainment, and other newsworthy subject matter. Portwars and Portwars.com is copyrighted, owned, and operated by Finium LLC. This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.  

1.  SCOPE AND UPDATES TO THIS PRIVACY POLICY        1

2.  PERSONAL INFORMATION WE COLLECT        2

3.  HOW WE USE YOUR PERSONAL INFORMATION        5

4.  HOW WE DISCLOSE YOUR PERSONAL INFORMATION        7

5.  YOUR PRIVACY CHOICES AND RIGHTS        8

6.  SECURITY OF YOUR INFORMATION        10

7.  INTERNATIONAL DATA TRANSFERS        10

8. CHILDREN’S INFORMATION        11 

9. OTHER PROVISIONS        11 

10. CONTACT US        11 

1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by Portwars, including on our websites, mobile applications, software, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, platform, mobile applications, software, and other offerings are collectively referred to here as the “Services.”  

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. Generally speaking, we collect personal information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations. See below for more details regarding each category.

A. Personal Information You Provide to Us Directly 

We may collect personal information that you provide to us, such as:

• Account Creation. We may collect personal information when you create an account, such as your email address, age, password, optional phone number for multi-factor authentication, and the username you will present to other users.

• Third-Party Services Information. Our platform may allow you to connect to an existing third party account that you control, such as a brokerage account, in order to access certain features.

Although by default we do not store your third-party’s login credentials or any banking/payment information, we do maintain metrics that track your communications with that third party while using our platform.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features, including but not limited to realtime chat communications made in connection with our video content. For example, our Services may include an “About Me” page, where you can choose to share your milestones and progress with other users and/or select an avatar image. Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users. 

• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or text message alerts, request customer or technical support, or otherwise communicate with us.

• Surveys and Polls. We may contact you to participate in surveys or polls. If you decide to participate, we may collect personal information from you in connection with the survey or poll.

• Promotions, Sweepstakes or Contests. We may collect personal information you provide for any promotions, sweepstakes, or contests that we offer. In some jurisdictions, we are required to publicly share information of promotion, sweepstakes, and contest winners.

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.  

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.  

• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.  

B. Personal Information Collected Automatically  

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.  

 o Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.

• Cookies and Other Technologies (Cookie Policy). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (collectively, “Technologies”) to automatically collect information through your use of our Services.  

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:  

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.  

Some of the advertising Technologies we use include, but are not limited to Meta, Google, AppLovin, LiveRamp, Criteo, Microsoft, and their partners. Click each partner’s name for more information regarding their privacy practices.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. 

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:

• Firebase/Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here. 

• Social Media Platforms. Our Services may contain social media buttons, such as Twitter, Instagram, TikTok, and YouTube, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Personal Information Collected from Other Sources 

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.  

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services 

We use your information to fulfil our contract with you and provide you with our Services, such as:

• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;  
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for promotions and events.

B. Administrative Purposes 

We use your information for various administrative purposes, such as: 

• Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;  
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Services;  
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services 

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.  

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.  

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.  

D. With Your Consent 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes 

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• Automated Decision Making. We may engage in automated decision making, including profiling. For example, we may engage in automated decision making to recommend certain videos for you to watch on our Services. Portwars’ processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

• De-identified and Aggregated Information. We may use personal information to create deidentified and/or aggregated information (for example, aggregate reports detailing the total number

of users we have in a given jurisdiction). We may share those de-identified/aggregated records with third parties, including our advertising partners.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.  

A. Disclosures to Provide our Services 

The categories of third parties with whom we may share your personal information are described below.  

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes but is not limited to service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

• Affiliates. We may share your personal information with our company affiliates (our “Affiliates”) for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.

• Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services and the general public).

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”  

• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.  

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers 

If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase, or sale of assets or all or parts of our business, or transition of service to another provider, your information may be sold or transferred in connection with such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.  

• Email Communications. 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. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our agreements, Terms, or this Privacy Policy).  

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

• Push Notifications. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.

• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. 

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.   

Please note you must separately opt out in each browser and on each device.  

• “Do Not Track” / “Global Privacy Control.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as a Do Not Sell request where required under applicable law, and we will also interpret it as a request to limit the sale or sharing of personal information for targeted advertising for residents of the European Economic Area, the UK, China and Brazil.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;  

• Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;  

• Request Restriction of or Object to our processing of your personal information when processing is noncompliant;  

• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;

• Request data portability and receive an electronic copy of personal information that you have provided to us; 

• Be informed about third parties with which your personal information has been shared; and

• Request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.

If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS  

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses. 

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.  

8.   CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

9.   OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.  

Supervisory Authority. If your personal information is subject to the applicable data protection laws of Australia, Brazil, the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.  

• Office of the Australian Information Commissioner 
• Autoridade Nacionalde Proteçãode Dados (ANPD)  
• EEA Data Protection Authorities (DPAs) 
• Swiss Federal Data Protection and Information Commissioner (FDPIC) 
• UK Information Commissioner’s Office (ICO) 

10.   CONTACT US  

Portwars is the controller of the personal information we process under this Privacy Policy.  

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Portwars

Attn: Finium LLC Privacy Agent

Finium@portwars.com