Privacy and Biometrics Policy

US Bullion Trust LLC’s Privacy Policy

Last modified: November 8, 2023

This privacy policy (“Policy”) describes the manner in which US Bullion Trust LLC (“USBT,” “we,” or “us”) collects, uses, maintains, and discloses information when you use our websites, hosted applications, mobile or other downloadable applications, and other services provided by us (collectively, the “Service”).

 

Please read this Policy carefully to understand our practices regarding your information. By clicking “I Accept,” or by downloading, installing, or otherwise using the Service, you agree to this Policy. If you do not agree to this Policy, you may not use or access our Service.

 

Our Service is intended for use by adults and may not be used by anyone under the age of 18. If you are under the age of 18, you may not access the Service.

 

Third-Party Links

Our Service may contain links to other websites or services provided by third parties. We may also partner with third parties that may use technologies such as cookies, widgets, and links to gather information about users on our Service. We do not have control over third party websites or services, and any third party website or services privacy practices are not governed by this Policy. Any time you leave our Service to a third party website or service, or interact with a third party link or other technology, you should exercise caution and review the privacy statement applicable to such third party websites or services to learn more.

 

Collection, Use & Sharing of Information

We may collected certain information when you use or access our Service. “Personal Information” is information that can be used to identify an individual. Below are specific examples of the Personal Information we may collect. Personal Information does not include information that has been de-identified or aggregated and that cannot reasonably be used to identify an individual. We may use and share de-identified or aggregated information for any purpose.

 

Categories of Personal Information We Collect:

• Identifiers, such as name, date of birth, postal address, e-mail address, telephone number, and internet protocol address, that you may provide when creating an account on or using our Service.

• Textual or photographic content that you may provide or generate when creating an account on or interacting with our Service.

• Internet or other similar network activity, including browsing history, search history, links, and information regarding your interaction with an internet website, application, or advertisement.

• Financial Information, such as PayPal information, bank account numbers, and other financial account numbers, may be collected when users create accounts on our Service or make requests through our Service.

• Geolocation data may be gathered when users interact with our Service, including IP addresses which provide information about users’ approximate location.

• Biometric identifiers and information that you may provide when verifiying your account through our third party services provider, Plaid Inc., when accessing or using our Service. Please read our biometric privacy notice below to learn more.

 

Sources for Personal Information We Collect:

• We receive Personal Information from individuals through their direct interactions with and access to our Service, including when creating an account on our Service.

• We receive Personal Information, such as technical data, usage data, and internet and other similar network activity, through automated technologies, such as cookies, flash cookies, and web beacons, and other interactions with our Service.

• We receive Personal Information from our service providers, business partners, and other third parties.

 

Our Business or Commercial Purposes for Collecting Personal Information and Categories of Third Parties to Whom the Information is Disclosed:

• Identifiers are collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share identifiers with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., our third party partners that assist us in providing the Service, and to any party with your consent.

• Audio and textual content is collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share identifiers with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., our third party partners that assist us in providing the Service, and to any party with your consent.

• Internet or other similar network activity is collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share internet or other similar network activity with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., our third party partners that assist us in providing the Service, and to any party with your consent.

• Financial Information is collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share financial information with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., our third party partners that assist us in providing the Service, and to any party with your consent

• Geolocation data is collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share geolocation data with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., our third party partners that assist us in providing the Service, and to any party with your consent.

• Biometric identifiers and information are collected to provide individuals with our Service, to improve the quality, safety, and security of the Service, to customize the Service, to administer and process requests related to the Service, to respond to direct inquiries, and for any other purpose to which you consent. We may share biometric identifiers with our subsidiaries and affiliates, our employees, our contractors, our service providers, including Plaid Inc., and to any party with your consent.

 

In addition, where consistent with applicable laws and regulations, we may disclose Personal Information in all categories above:

• to prepare, negotiate, or perform a contract with you;

• to respond to subpoenas, court orders, or other legal process or otherwise as required by law or the competent government or judicial authorities;

• to establish or preserve a legal claim or defense;

• as part of corporate restructuring, sale of assets, merger, or divestiture; or

• to prevent fraud or other illegal activities, such as willful attacks on our information technology systems.

 

Sale and Marketing of Personal Information

We do not sell your Personal Information to others. We do not disclose any Personal Information to third parties for their direct marketing purposes.

 

Choices and Access Concerning Your Personal Information

Your choices regarding our use and disclosure of Personal Information

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt out from receiving communications from us by contacting us at [insert support email]. If you no longer want to receive promotional-related emails from us, you may opt out according to instructions in such communications. Please note that if you opt out of receiving certain communications, we may still send you important administrative messages and alerts, including message about your account.

Access, change, or deletion of Personal Information

To the extent applicable law provides you with the right to review, correct, update, or delete Personal Information that you previously have provided to us, please contact us using our contact information below should you wish to do so. We will respond to your request consistent with applicable law.

California Shine the Light Law

Under California law, California residents have the right to request in writing from businesses with whom they have an established business relationship certain information pertaining to third parties to which the business discloses personal information for marketing purposes. To request further information regarding the California Shine the Light Law, please contact us using the information below.

 

Data Integrity

The security of your Personal Information is important to us.  We employ a number of organizational, technical, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your Personal Information. Your submission of any Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Data Retention

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Data Relating to Children Under the Age of 18

Children under the age of 18 are prohibited from using or accessing the Services, including our mobile application and website. Our Services are not intended for or directed at anyone under the age of 18 (or such other age as may be restricted under local law). If we are made aware that we have received information in violation of our Policy, we will use reasonable efforts to locate and remove that information from our records.

If you believe that your child’s information is contained on our Services in violation of this Policy and wish to have it removed, please contact us using our contact information listed below.

 

Changes to Our Privacy Policy

This Privacy Policy may change from time to time. We reserve the right to make any changes, modifications, additions, or deletions to this Policy at any time. If we make material changes to privacy practices, we will notify you by email or through a notice on this page. The date the Policy was updated is at the top of this page. We encourage you to periodically check this page for updates.

 

BIOMETRIC PRIVACY NOTICE

 

This Biometric Privacy Notice applies to the processing your biometric information by USBT for purposes of verifying your identity in connection with your use of the Service. Certain portions of our Service are offered through our third party vendor, Plaid Inc. (“Plaid”). Plaid may verify your identity by comparing a photograph or ID containing your face to a photograph, selfie, or video of yourself to compare certain points, regions, “liveness,” and data from your face to verify a match (“facial match data”) for purposes of verifying your identity. The facial match data, and any documents or information generated by the facial match data, may be considered biometric data or biometric information pursuant to certain states’ laws, including the Illinois Biometric Information Protection Act (“BIPA”). To review Plaid’s privacy policy, please click here [insert link to Plaid privacy policy].

USBT does not receive, collect, store, or otherwise obtain the facial match data from Plaid. Any documents or information generated by the facial match data and obtained by USBT are securely stored by USBT for up to one year, unless you instruct USBT to delete such documents or information sooner. USBT utilizes reasonable technical and administrative measures to protect any documents or information generated by the facial match data from unauthorized disclosure.

The facial match data is only used for identify verification purposes in connection with our Service.

USBT does not sell, lease, trade, or otherwise profit from facial match data or any documents or information generated by facial match data. USBT does not authorize its vendors to sell, lease, trade, or otherwise profit from facial match data or documents or information generated by facial match data. Facial match data and documents and information generated by the facial match data may be accessed by USBT and its vendor(s), including Plaid Inc. USBT may share facial match data and documents and information generated by facial match data only as described in this Biometric Privacy Notice and will not otherwise share it unless:

• The user or the user’s authorized representative provides written consent to sharing;

• Disclosure is permitted or required by applicable law or is in response to subpoenas, court orders, or other legal processes.

 

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at [insert contact email].

Account Deletion Policy

You have the right to request the deletion of your account and associated data at any time. To delete your account, simply navigate to the settings section and click on the "Delete Account" button. If you prefer, you can also request account deletion by sending an email to support@goldreliance.com.your privacy is important to us, and we will handle your request promptly.