**PRIVACY POLICY**

**Last Updated: 10/01/2024**



GA TRADING LLC (collectively, “GA Trading,” “our,” “we,” or “us”) values and respects the privacy of its customers and visitors. While operating our business and interacting with you, we collect, use, and share personal information as disclosed in this privacy policy (“Privacy Policy”).





This Privacy Policy provides you with detailed information about how GA Trading and its subsidiaries, divisions, affiliates, brands and other companies that link to this Privacy Policy collect, use, share, and protect your information, and describes your choices and rights. This Privacy Policy also applies to information we receive from business partners and other third parties. We encourage you to read this Privacy Policy carefully and if you have any questions to contact us using the methods listed below.



We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on our website: www.nebroo.com (“Site”) and we will alert you that there has been a change by updating the “Last Updated” date displayed on the Privacy Policy. If GA Trading determines that such changes materially affect your privacy rights, we will provide additional notice to you.



Collecting Your Information

We may collect information about you in a variety of ways, including when you provide information directly to us, when you visit our Site, or when we receive your information from other sources, such as our trusted third-party providers. The categories of information we collect, including in the last 12 months, include:





Categories of Information You May Provide to Us. This is information that you choose to provide in connection with creating an account, providing content on the Site, or your other activities on the Site. Categories of information you provide to us include: (1) commercial information, such as date of purchase, items purchased, and purchase amount; (2) customer service information, such as feedback and surveys; and (3) contact information, such as your name, email, phone number, and residential address.





Categories of Information We Collect About You. Our servers automatically collect information when you contact us or when you visit, use, or browse the Site. We may also collect information about you from our third-party providers. Categories of information we collect about you include: (1) device information, such as your IP address, operating system, browser version, language preferences, referring URLs, country, and location; (2) analytics data and inferences about your purchases and Site usage; (3) contact information, such as your name, email address, phone number, and mailing address; and (4) browsing information, such as the pages you visit on the Site, the dates and times you visit the Site, information about how and when you use our Site, and other technical information.





If you access the Site from a mobile device, we will collect information about the type of mobile device you use. We do not collect any “sensitive personal information” or “sensitive data” as these terms are defined under applicable law.





Using Your Information

We process information for business and commercial purposes in accordance with this Privacy Policy. Our business purposes for collecting and using your information include the following:

Manage and Improve our Business. We use information to help operate and increase the efficiency of our business, and to improve our products and services.

Analytics. We may monitor and analyze usage and trends to compile statistical information which we may use internally or provide to third parties.

Facilitate Transactions and Customer Service. We use your information to complete purchases, to operate and personalize the Site, to send you confirmations and administrative messages, and to perform our customer service functions.

Marketing and Advertising. We use your information to market our services to you, and to deliver information to you that we think may be of interest to you, such as articles, news, or information about various promotions and products.

Security and Fraud Prevention. We use your information to perform security and fraud prevention functions for the Site.

Required by Law. We collect and use your information as required by law, for compliance purposes, or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of GA Trading or others, as we deem appropriate.





Sharing Your Information

We may share the categories of information described above with third parties that perform services for us or on our behalf. The categories of third parties that we share information with, including in the past 12 months, include: (1) service providers and suppliers; (2) marketing partners and advertising networks; (3) data analytics providers; (4) payment processing providers; (5) our affiliates and subsidiaries; (6) social networks; and (7) other parties in connection with business transfers and for legal, safety, fraud prevention, and enforcement reasons. We do not control these third parties or how information is used.





We share the categories of information described in this Privacy Policy with third parties for the following business purposes:

Manage and Improve our Business. We share your information with third party service providers that help us operate and increase the efficiency of our business and help us improve our products and services.

Analytics. We may allow third-party service providers to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Facilitate Transactions and Customer Service. We may share information with third-party providers that help us process payments, provide the Site, and perform customer service functions.

Marketing and Advertising. We share information with third-party providers that support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, advertising networks or any other activity that may be considered cross-behavioral advertising or direct marketing.

Security and Fraud Prevention. We share information with third parties that provide security and fraud protection to GA Trading.

Required By Law. We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process, or as we deem necessary to investigate or remedy any actual or potential violation of our policies, or to protect the rights, property, and safety of GA Trading or others, as we deem appropriate.

Transfer of Assets. If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.





In the past 12-months, we have transferred the following categories of information to third parties identified in this Section for marketing and advertising purposes: (1) persistent identifiers, such as unique device identifiers, email addresses, account information, IP addresses, information related to your browser and operating system, or any information that you provided through the Site; and (2) user activity data, such data generated through your activities on the Site. In some jurisdictions, the transfer of information to third-party providers for marketing and advertising purposes could be defined as a “sale”, sharing for “cross-context behavioral advertising” or targeted advertising. However, we generally do not sell information as the term “sell” is traditionally understood.





We may also disclose the categories of personal information described in this Privacy Policy for commercial purposes described in this Privacy Policy. We may disclose these categories of personal information for the business and commercial purposes described in this Privacy Policy to the extent permitted by applicable law to the categories of third parties described in this Privacy Policy.





Cookies, Web Beacons, and Tracking Technologies

The Site uses cookies, web beacons, and other tracking technologies in order to collect, use, and share your information as described in this Privacy Policy. These technologies are useful for storing your preferences and settings, enabling you to sign-in, gathering information such as browser type and operating system, providing interest-based advertising, combating fraud, analyzing how our Site or services perform, and fulfilling other legitimate purposes.





Cookies used on this Site may include: (1) required cookies used to perform essential website functions, such as storing your preferences and settings; (2) social media cookies to show you ads and content based on your social media profiles and activities on other websites; (3) analytics cookies to better understand how you use the Site and to improve our Site and services; (4) advertising cookies to show you ads that are relevant to you. If you previously provided information to us, a unique identifier in the cookie may associate the information collected via the cookie with your information. We may share aggregate cookie and tracking information that does not directly identify you with third parties.





Some content on the Site may be provided by third parties that use cookies in conjunction with other tracking technologies to collect information about you when you use the Site, which enables them to provide targeted advertising to you. We do not control these third parties’ tracking technologies or how they may be used. We may display certain advertising offers on the Site or allow service providers, advertisers, ad networks, or other third parties to advertise on the Site. Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies, web beacons, or similar tracking technology to help manage and optimize your online experience with us. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we’ve collected from cookies prior to you disabling them; however, we will not collect any further information from the disabled cookies.





Policy for Children

We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.





SMS Messaging

By signing up to any of our promotional lists, you are giving your express permission to GA Trading and its agents or vendors the right to contact you with targeted advertising materials by email, text message (SMS), telephone or cellphone, including the use of automated, predictive, programmable, or similar automatic dialers or dialing software, or any other means of communication we may utilize to provide promotional offers. Your consent is not a condition of purchase. To the extent applicable, you expressly acknowledge that you are solely responsible for all charges billed by your mobile service provider. If you no longer wish to receive promotional communications by email, please follow the unsubscribe link located at the end of an email message. If you no longer wish to receive promotional text messages, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from GA Trading. We may share your data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.





Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals but do recognize and respond when required by applicable privacy laws, such as when HTTP header fields or Java objects are used.





Submitting Information from Outside the United States

We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the Site may be stored and processed in the United States or any other country in which our vendors or we maintain facilities. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.





Links to Other Websites and Third-Party Practices

This Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.





Your Privacy Rights

Where applicable based on privacy laws in your jurisdiction, you may have certain rights you can request that we fulfill. These rights may include:

The Right to Know. You have the right to request that we disclose the information that we have collected about you and identify the purposes for which the information was used, whether and to whom it was shared, and what sources it was obtained from.

The Right to Delete. You have the right to request that we delete information that we maintain about you, subject to certain exceptions.

The Right to Correct. You have the right to correct any information that we store about you.

The Right to Opt-Out of Your Personal Information Being Sold or Shared. You may opt-out of us sharing or selling your information by contacting us at info@nebroo.com or visiting our “

Do Not Sell or Share My Personal Information” page.

Right to Opt-Out of Targeted Advertising. You have the right to request that we opt you out of targeted advertising.

Right Not to Receive Discriminatory Treatment. Exercising your rights under this Privacy Policy will not result in any discrimination by us. We will treat you the same as any other user.

Right to Complain. You have the right to complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority.

Right to Data Portability. You have the right to request that we provide you with a copy of your information on file with us.

Right to Appeal. If you make a request to exercise any of the applicable data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing us at info@nebroo.com with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your state’s Attorney General to file a complaint.





How to Exercise Your Privacy Rights

In order to exercise any of the rights detailed in this Privacy Policy, please contact us at info@nebroo.com. You can exercise your right to opt-out of selling or sharing your Personal Information by visiting out or visiting our “

Do Not Sell or Share My Personal Information” page.





We may require additional information from you to help us verify your identity and state or country of residence, and to process your request. The verification steps may vary depending on the sensitivity of the information and whether you have an account with us. If we are unable to verify your identity, we may deny your requests to know or delete.





You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting us at info@nebroo.com.





CALIFORNIA SHINE THE LIGHT

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, please contact us via email at info@nebroo.com.





Retention Period

We shall only store the information we collect for as long as it is necessary to complete the commercial purposes for which it was collected. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on: (1) the nature of our relationship with the data subject, and (2) any legal obligations we are bound to fulfill.



Contact Us

If you have questions or comments about this Privacy Policy, please send us an email at info@nebroo.com. If you prefer, you may also contact us via physical mail at: 1768, 701 Tillery Street Unit 12, Austin, TX, Travis, US, 78702