Privacy Policy

Policy pending counsel review. 1/10/2025

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This Privacy Policy (“Policy”) only applies when GTCX Sovereign, Inc (referred to as either "the Company", "We", "Us" or "Our" in this Policy) is the Controller of personal data (example: GTCX Sovereign, Inc website visitors’ personal data and business-to-business contact data). GTCX Sovereign, Inc is a Processor, not a Controller, of personal data that we process on behalf of our Customers when they use GTCX Sovereign, Inc. products and Services. If you have questions related to how a GTCX Sovereign, Inc Customer utilizes your personal data, please contact them directly. We are not responsible for the privacy or data security practices of our Customers. This Policy also does not apply to personal data about current and former GTCX Sovereign, Inc employees, job candidates, or contractors and agents acting in similar roles.

1. Introduction

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This Policy only applies to personal data that GTCX Sovereign, Inc handles as a Controller (meaning where GTCX Sovereign, Inc controls how and why your personal data is processed). This includes when you:

• Visit or interact with the GTCX Sovereign, Inc website, our branded social media pages, and other Sites which we operate (collectively, our “Digital Properties”);
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2. Changes to this Privacy Policy

3. Personal Data We Collect and Disclose

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4. How We Process Personal Data

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5. Sources of Personal Data

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6. Cookies and Tracking Technologies

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7. Security and Retention

8. Children's Privacy

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9. External Links

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10. Supplemental Terms for California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), this Section 10 applies to certain personal data collected about California individuals where GTCX Sovereign, Inc. controls how and why the personal data is processed (which the CCPA calls a “business”) and supplements the rest of our Policy above. This Section 10 does not apply to current or former employees, applicants, contractors, or agents.

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Although we have not “sold” or “shared” personal data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or “sharing” as defined under California law. We do not knowingly sell or share any personal data of minors under the age of 18. We do not collect or process “sensitive personal information,” as defined by California law, to infer characteristics about you. GTCX Sovereign, Inc. only uses sensitive personal information consistent with the exceptions to the right to limit sensitive personal information.

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11. Supplemental Information for the EEA, Switzerland, and the U.K.

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12. Supplemental Information for Other Regions

• ———Personal data collected, stored, used, and/or processed by GTCX Sovereign, Inc., as described in this Policy, is collected, stored, used, and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles. If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed on——————
• ———Personal data, as defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) will be collected, stored, used, and/or processed by GTCX Sovereign, Inc. in accordance with the GTCX Sovereign, Inc.’s obligations under PIPEDA.
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• ———Personal data collected, stored, used, and/or processed by GTCX Sovereign, Inc., as described in this Policy, is collected, stored, used, and/or processed in accordance with New Zealand’s Privacy Act 2020 and its 13 Information Privacy Principles (“NZ IPPs”).
• ———Personal data collected, stored, used and/or processed by GTCX Sovereign, Inc., as described in this Policy, is collected, stored, used, and/or processed in accordance with GTCX Sovereign, Inc.’s obligations under the Personal Data Protection Act 2012 (“PDPA”).
• ———Personal data collected, stored, used, and/or processed by GTCX Sovereign, Inc., as described in this Privacy Policy, is collected, stored, used, and/or processed in accordance with GTCX Sovereign, Inc.’s obligations under the UK Data Protection Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019, as amended, superseded or replaced (“U.K. GDPR”).

13. Contact Information

If you have questions or complaints regarding this Policy or about the GTCX Sovereign, Inc.’s privacy practices, please contact us by reaching out via one of the communication channels below: