PRIVACY POLICY

Last updated: April 5, 2018

Totle, Inc. ("Totle") provides a service that allows users to manage their crypto assets. This Privacy Policy explains how information about you is collected, used and disclosed when you use our websites, mobile applications, and other online services that link to this Privacy Policy (collectively, the "Services") or when you otherwise interact with us. By submitting personal information to us or by otherwise using our Services, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy (as may be amended from time to time). If you do not agree with some or all of this Privacy Policy, please do not use our Services.

We may change this Privacy Policy from time to time. If we make
changes, we will notify you by revising the date at the top of the policy and,
in some cases, we may provide you with additional notice (such as adding a
statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise
interact with us to stay informed about our information practices and the ways
you can help protect your privacy.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example,
we collect information when you create an account, verify your identity, link
accounts, enter your credentials, participate in any interactive features of
the Services, fill out a form, participate in a contest or promotion, apply for
a job, communicate with us via third party social media sites, request customer
support or otherwise communicate with us. The types of information we may
collect include your name, email address, password, postal address, phone
number, date of birth and any other information you choose to provide.

Information from Your Device

With your permission, we may access files on your device, such as your contacts, photos, or camera, to enable features of the Services. We may also access information about your precise location.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

We and our service providers may use information we collect to provide, maintain, and improve our Services, including to administer contests and promotions and to connect crypto asset companies with users who may be interested in investing with them. To do this, we use your personal information to communicate with you about our Services and the products and services of other companies. We also use your information as follows:

Totle is based in the United States and the information we
collect is governed by U.S. law. By accessing or using the Services or
otherwise providing information to us, you consent to the processing and
transfer of information in and to the U.S. and other countries.

Disclosure or Sharing of Information

As noted above, we use your personal information to communicate
with you about information and offers from our crypto asset partners, but we do not share your information with our partners to allow them to communicate with you directly. We may share information about you as follows or as otherwise described in this Privacy Policy:

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" button), which allows you to share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Totle and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your mobile device may also give you the option to opt out of the use of information about the apps you use to serve ads that are targeted to your interests (called “Opt out of Personalized Advertising” on Android devices and “Limit Ad Tracking” on iOS devices).

Security

Totle takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Account Information

Totle takes reasonable steps to ensure that any personal information in our custody is accurate and up-to-date for the purposes for which the personal information is to be used by Totle. In most instances, we rely on users to notify us of any changes to their personal information. You may update, correct or delete information about you at any time by logging into your online account or emailing us at admin@totle.com. If you wish to delete your account, please email us at admin@totle.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional emails from Totle by following the instructions in those emails or other messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional
push notifications or alerts to your mobile device. You can deactivate these
messages at any time by changing the notification settings on your mobile
device.

Location Information

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Contact us

Accountability with respect to your personal information is important to Totle. In the event that you have any questions (including how personal information is managed by Totle), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and our responsibilities under this Privacy Policy can be directed to admin@totle.com.