Immortal Capital Ltd, (hereinafter also referred to as “Company”, “Immortal Capital” “we”,
“our” or “us”) operates www.immortalcapitalltd.com (“Website”) and Immortal Capital
services (collectively “Services”). Our Privacy Policy (“Policy”) governs your visit to our
Website and explains how we collect, safeguard and disclose information that results from your
use of our Service.
We take your privacy very seriously. In this Policy, we seek to explain to you in the clearest way
possible what information we collect, how we use it and what rights you have in relation to it.
We hope you take some time to read through it carefully, as it is important. If there are any terms
in this Policy that you do not agree with, please discontinue the use of our Services immediately.
We use your data to provide and improve Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in this
Policy, the terms used in this Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions govern all use of our Service and together with the Policy constitute
your agreement with us.
If this Policy is modified in any way, it will be updated here. Regularly checking and reviewing
this page ensures that you are updated on the information which may be collected, used and
shared with other parties. If we believe that the modifications are material, we will notify you of
the changes by posting a notice on the Website, or emailing you at the email address provided to
us by you, and as we may deem appropriate. What constitutes a material change will be
determined by us, at our sole and absolute discretion. In this Policy "you", "your", “user” and
“users” refers to the users of the Website.
WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us
We may collect personal information that you voluntarily provide to us when you visit the
Website, express an interest in obtaining information about us or our Services or otherwise when
you contact us.
The personal information that we may collect depends on the context of your interactions with us
and the Website, the choices you make and the services and features you use. The personal
information we collect may include the following:
Personal Information Provided by You. We collect Name; Email addresses; and other similar
information. We may also collect additional information about our clients in order to provide
relevant and effective services.
Information automatically collected
When you access our websites, we, our service providers and our partners may automatically
collect information about you, your computer or mobile device, and your activity on our
websites. Typically, this information includes your computer or mobile device operating system
type and version number, manufacturer and model, device identifier (such as the Google
Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the
website you visited before browsing to our website, general location information such as city,
state or geographic area; and information about your use of and actions on or in our websites,
such as pages or screens you accessed, how long you spent on a page or screen, navigation paths
between pages or screens, information about your activity on a page or screen, access times, and
length of access.
Our service providers and business partners may collect this type of information over time and
across third-party websites. This information is collected via various mechanisms, such as via
cookies, web beacons, embedded scripts, and similar technologies. This type of information may
also be collected when you read our HTML-enabled emails.
The information we collect includes:
● Log and Usage Data. Log and usage data is service-related, diagnostic usage and
performance information our servers automatically collect when you access or use our
Website and which we record in log files. Depending on how you interact with us, this
log data may include your IP address, device information, browser type and settings and
information about your activity on the Website (such as the date/time stamps associated
with your usage, pages and files viewed, searches and other actions you take such as
which features you use), device event information (such as system activity, error reports
(sometimes called 'crash dumps') and hardware settings).
● Device Data. We collect device data such as information about your computer, phone,
tablet or other devices you use to access the Website. Depending on the device used, this
device data may include information such as your IP address (or proxy server), device
application identification numbers, location, browser type, hardware model Internet
service provider and/or mobile carrier, and operating system configuration information.
HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Website for a variety of business purposes
described below. We process your personal information for these purposes in reliance on our
legitimate business interests, in order to enter into or perform a contract with you, with your
consent, and/or for compliance with our legal obligations. We indicate the specific processing
grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
● To provide our services to you. We may use your personal information to provide our
services to you.
● To send administrative information to you. We may use your personal information to
send you product, service and new feature information and/or information about changes
to our terms, conditions, and policies.
● To protect our Services. We may use your information as part of our efforts to keep our
Website safe and secure (for example, for fraud monitoring and prevention).
● To enforce our terms, conditions and policies for business purposes, to comply with legal
and regulatory requirements or in connection with our contract.
● To respond to legal requests and prevent harm. If we receive a subpoena or other legal
request, we may need to inspect the data we hold to determine how to respond.
● To respond to user inquiries and support users. We may use your information to
respond to your inquiries and solve any potential issues you might have with the use of
our Services.
● To send you marketing and promotional communications. We and/or our third-party
marketing partners may use the personal information you send to us for our marketing
purposes if this is in accordance with your marketing preferences. For example, when
expressing an interest in obtaining information about us or our Website, subscribing to
marketing or otherwise contacting us, we will collect personal information from you. You
can opt-out of our marketing emails at any time.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share the data that we hold based on the following legal basis:
● Consent: We may process your data if you have given us specific consent to use your
personal information for a specific purpose.
● Legitimate Interests: We may process your data when it is reasonably necessary to
achieve our legitimate business interests.
● Performance of a Contract: Where we have entered into a contract with you, we may
process your personal information to fulfil the terms of our contract.
● Legal Obligations: We may disclose your information where we are legally required to
do so in order to comply with applicable law, governmental requests, a judicial
proceeding, court order, or legal processes, such as in response to a court order or a
subpoena (including in response to public authorities to meet national security or law
enforcement requirements).
● Vital Interests: We may disclose your information where we believe it is necessary to
investigate, prevent, or take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to the safety of any person and
illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the
following situations:
● Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company.
● Third-Party Advertisers: We may use third-party advertising companies to serve ads
when you visit or use the Website. These companies may use information about your
visits to our Website(s) and other websites that are contained in web cookies and other
tracking technologies in order to provide advertisements about goods and services of
interest to you.
● Affiliates: We may share your information with our affiliates, in which case we will
require those affiliates to honour this Policy. Affiliates include our parent company and
any subsidiaries, joint venture partners or other companies that we control or that are
under common control with us.
● Business Partners: We may share your information with our business partners to offer
you certain products, services or promotions.
USE OF COOKIES, WEB BEACONS AND OTHER TRACKERS
We use temporary and permanent cookies, tags, scripts, and other similar technologies to identify
users of our services and enhance user experience and identify visitors, track website navigation,
gather demographic information about visitors and users, understand email campaign
effectiveness and for targeted visitor and user engagement by tracking your activities on our
websites. We use third-party tracking services like google analytics and google tag manager to
understand the behaviour of our website visitors and serve them better.
Further, the pages on the website may also include web beacons or pixels, which are electronic
files to count users who have visited that page, to track activity over time and across different
websites, to determine users’ interactions with emails we send, to identify certain cookies on the
computer or other electronic device accessing that page, or to collect other related information,
and this information may be associated with your unique browser, device identifier, or Internet
Protocol address.
You can set your browser to refuse all cookies or to indicate when a cookie is being sent to your
computer. However, this may prevent our site or services from working properly. You can also
set your browser to delete cookies every time you finish browsing. For more information please
refer to our Cookies Policy.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
The Website may contain third parties links and which may link to other websites like Instagram,
Facebook etc. We cannot guarantee the safety and privacy of the data you provide to any third
parties. Any data collected by third parties is not covered by this Policy. We are not responsible
for the content or privacy and security practices and policies of any third parties, including other
websites, services or applications that may be linked to or from the Website. We strongly advise
you to review the Privacy Policy of every site you visit. We have no control over and assume no
responsibility for the content, privacy policies or practices of any third-party sites or services.
WE HEREBY DISCLAIM LIABILITY FOR, ANY INFORMATION, MATERIALS,
PRODUCTS, OR SERVICES POSTED OR OFFERED AT ANY OF THE THIRD-PARTY
SITES LINKED TO THIS WEBSITE. BY CREATING A LINK TO A THIRD-PARTY
WEBSITE, WE DO NOT ENDORSE OR RECOMMEND ANY PRODUCTS OR SERVICES
OFFERED OR INFORMATION CONTAINED ON THAT WEBSITE, NOR ARE WE LIABLE
FOR ANY FAILURE OF PRODUCTS OR SERVICES OFFERED OR ADVERTISED AT
THOSE SITES. SUCH A THIRD PARTY MAY HAVE A PRIVACY POLICY DIFFERENT
FROM THAT OF OURS AND THE THIRD-PARTY WEBSITE MAY PROVIDE LESS
SECURITY THAN THIS SITE.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set
out in this Policy, unless a longer retention period is required or permitted by law. No purpose in
this Policy will require us keeping your personal information for longer than the period of time in
which users have an subscription with us.
When we have no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to
protect the security of any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our
security, and improperly collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal information to and from
our Website is at your own risk. You should only access the Website within a secure
environment.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA
PROTECTION REGULATION (GDPR).
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have
certain data protection rights, covered by GDPR. We aim to take reasonable steps to allow you to
correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed of what
Personal Data we hold about you and if you want it to be removed from our systems, please
contact us.
Under certain circumstances, individuals in Europe have rights under data protection laws in
relation to their personal data. If you are located in Europe, you may ask us to take the following
actions regarding personal data that we hold:
1. Access. You are entitled to ask us if we are processing your personal data and, if so, for a
copy of the personal data we hold about you, as well as obtain certain other information
about our processing activities.
2. Correction. If any personal data we hold about you is incomplete or inaccurate, you can
require us to correct it, though we may need to verify the accuracy of the new data you
provide to us.
3. Erasure. This enables you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local law.
4. Object. Where our reason for processing your personal data is a legitimate interest you
may object to the processing as you feel it impacts your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct
marketing purposes.
5. Restriction. You may ask us to suspend our use of your personal data in the following
scenarios: if you want us to establish the data's accuracy; where our use of your personal
data is unlawful but you do not want us to erase it; where you need us to hold your data
for a longer period than we usually would, because you need it to establish, exercise or
defend legal claims; or you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
6. Transfer. Where it is possible, we will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to personal data provided by you which you initially provided
consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent. Where our reason for processing is based on your consent, you may
withdraw that consent at any time. If you withdraw your consent, we may not be able to
provide certain products or services to you. We will advise you if this is the case at the
time you withdraw your consent.
8. Automated decision making. You have the right not to be subject to automated
decision-making (e.g., profiling) that significantly affects you. The exercise of this right
is not available to you in the following cases:
a. The automated decision is required to enter into, or perform, a contract with you.
b. We have your explicit consent to make such a decision.
c. The automated decision is authorised by the local law of an EU member state.
However, in the first two cases set out above, you still have the right to obtain human
intervention in respect of the decision, to express your point of view and to contest the decision.
There may be legal or other reasons why we cannot, or are not obliged to, fulfil a request to
exercise your rights. We will use available lawful exemptions to your individual rights to the
extent appropriate. If we decline your request, we will tell you why, subject to legal restrictions.
You will not have to pay a fee to exercise any of your rights relating to your personal data.
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Please note that we may ask you to verify your identity before responding to such requests.
Please note, we may not be able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of
your Personal Data. For more information, please contact your local data protection authority in
the European Economic Area (EEA).
YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA
PRIVACY PROTECTION ACT (CalOPPA)
According to CalOPPA, we agree to the following:
1. our Privacy Policy link includes the word “Privacy”, and can easily be found on the home
page of our website;
2. users will be notified of any privacy policy changes on our Privacy Policy Page;
3. users are able to change their personal information by emailing us at the contact details
mentioned in the “Contact Us” clause.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do
Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web
browser to inform websites that you do not want to be tracked.
YOUR DATA PROTECTION RIGHTS UNDER CALIFORNIA
CONSUMER PRIVACY ACT (CCPA)/ CALIFORNIA PRIVACY RIGHTS
ACT (CPRA).
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of
all third parties to which we have disclosed certain information during the preceding year for
those third parties' direct marketing purposes.
California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The
CCPA, as amended by the CPRA, provides California residents and/or their authorized agents
with specific rights regarding the collection and storage of their personal information.
Your Right to Know: California residents have the right to request that we disclose the
following information to you about our collection and use of your personal information over the
past twelve (12) months. We may ask you to provide certain information to identify yourself so
that we may compare it with our records in order to verify your request. Upon verification, we
will disclose to you:
● The categories of personal information we have collected about you.
● The categories of sources for the personal information we have collected about you.
● The specific pieces of personal information we have collected about you.
● Our business or commercial purpose for collecting or selling your personal information.
● The categories of third parties to whom we have sold or shared your personal information
if any, and the categories of personal information that we have shared with each
third-party recipient.
Your Right to Opt-Out of Sale or Sharing of Personal Information: California residents have
the right to opt-out of the sale of their personal information by submitting a request as directed
on the homepage of our website or by contacting us using the information in the “Contact Us”
section below. Please note that we do not knowingly sell the personal information of any
individuals under the age of 18.
Where we are sharing your personal information with third parties for the purposes of
cross-context behavioural advertising or profiling, you may opt-out of such sharing at any time
by submitting a request as directed on the homepage of our website or by contacting us using the
information in the “Contact Us” section below.
Your Right to Limit Use of Sensitive Personal Information: California residents have the
right to request that we limit our use of any sensitive personal information to those uses which
are necessary to perform the Services or for other specifically-enumerated business purposes
under the CCPA, as amended by the CPRA.
Your Right to Delete: California residents have the right to request that we delete any of the
personal information collected from you and retained by us, subject to certain exceptions. We
may ask you to provide certain information to identify yourself so that we may compare it with
our records in order to verify your request. Once your request is verified and we have determined
that we are required to delete the requested personal information in accordance with the CCPA,
we will delete, and direct our third-party service providers to delete, your personal information
from their records. Your request to delete personal information that we have collected may be
denied if we conclude it is necessary for us to retain such personal information under one or
more of the exceptions listed in the CCPA.
Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have
the right to request that we correct any inaccurate personal information we maintain about you,
taking into account the nature of the personal information and the purposes for which we are
processing such personal information. We will use commercially reasonable efforts to correct
such inaccurate personal information about you.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of
your privacy rights conferred by the CCPA.
Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may
make a request related to your personal information. In the case of access and deletion, your
request must be verifiable before we can fulfil such a request. Verifying your request will require
you to provide sufficient information for us to reasonably verify that you are the person about
whom we collected personal information or a person authorized to act on your behalf. We will
only use the personal information that you have provided in a verifiable request in order to verify
your request. We cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority. Please note that we may charge a reasonable fee or
refuse to act on a request if such request is excessive, repetitive or manifestly unfounded. To
exercise these rights, please contact us at the contact information mentioned in the “Contact
Us” clause.
DATA PROTECTION RIGHTS FOR OTHER JURISDICTIONS
In Australia, data protection rights are governed by the Australian Privacy Principles (APPs).
These principles outline the rights and obligations regarding the collection, use, and disclosure of
personal information. Individuals have the right to know how their personal data is being
handled, access their personal information held by organizations, request correction of inaccurate
data, and make complaints about privacy breaches. The Office of the Australian Information
Commissioner (OAIC) is the regulatory authority responsible for overseeing data protection in
Australia. For more information on data protection rights in Australia, visit the website of the
OAIC at https://www.oaic.gov.au/.
In Switzerland, data protection rights are protected by the Swiss Federal Act on Data Protection
(FADP). Individuals have the right to know what personal data is being processed, access their
personal information, request the correction or deletion of inaccurate or outdated data, and object
to the processing of their data under certain circumstances. The Swiss Federal Data Protection
and Information Commissioner (FDPIC) is the authority responsible for enforcing data
protection regulations in Switzerland. For more information on data protection rights in
Switzerland, refer to the official website of the FDPIC.
For data protection rights for other jurisdictions, please refer to your country-specific data
protection laws.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-
Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
WHAT INFORMATION DO THE SERVICE PROVIDERS HAVE ACCESS TO?
We may use third-party companies and individuals to facilitate our Service ("Service
Providers"), to provide the Service on our behalf, to perform Service-related services or to assist
us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf
and are obligated not to disclose or use it for any other purpose.
GOOGLE ANALYTICS
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and
reports website traffic. Google uses the data collected to track and monitor the use of our
Service. This data is shared with other Google services. Google may use the collected data to
contextualise and personalise the ads of its own advertising network. You can opt-out of having
made your activity on the Service available to Google Analytics by installing the Google
Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy &
Terms web page: https://policies.google.com/privacy?hl=en
GOOGLE ADSENSE
Google AdSense is a program run by Google that allows website publishers to display targeted
ads on their websites and earn revenue from clicks or impressions.
To opt-out of personalized ads: Google provides an Ad Personalization settings page where you
can manage your ad preferences. This page allows you to control the information Google uses to
show you personalized ads. You can visit the Ad Personalization page within your Google
account settings to make these changes.
To learn more about Google's privacy practices: For detailed information about how Google
collects and uses data through AdSense, you can visit the Google Privacy & Terms web page
dedicated to advertising: https://policies.google.com/technologies/ads
PAYMENTS
We provide paid premium services. In that case, we use third-party services for payment
processing. (i.e Paypal)
We don’t store or collect your payment details. That information is provided directly to our
third-party payment processors whose use of your personal information is governed by their
Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed
by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard,
American Express and Discover. PCI-DSS requirements help ensure the secure handling of
payment information.
CHILDREN’S PRIVACY
We do not knowingly collect personally identifiable information from Children under 13 without
the parent's consent. If you become aware that a Child has provided us with Personal Data
without the parent's consent, please contact us. If we become aware that we have collected
Personal Data from Children, we take steps to remove that information from our servers.
DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by
an updated “Last updated” date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are protecting
your information.
CONTACT US
After reviewing this policy, if you have any additional questions, concerning this Privacy Policy,
please contact us by sending an email to hello@inmoratl.com by adding the word “Privacy” in
the subject line.
Last Updated: August 5, 2023.