Privacy Policy

Last modified: June 2, 2025

Matrix Global LLC (“Company” or “We”, “Our” or “Us”), a Cook Islands company, respects your privacy and is committed to protecting it through Our compliance with this policy. 

This policy describes the types of information We may collect from you or that you may provide, and Our practices for collecting, using, maintaining, protecting, and disclosing that information, when you visit the website virginiamonthly.com (together with all subdomains, “Site”) or access or use any content, functionality, and services offered on or through the Site (collectively, the “Services”) that reference this privacy policy (the “Terms”).

These Terms constitute a legally binding agreement made between you, whether personally or on behalf of an entity, and Company concerning your access to and use of Our Services. By accessing and continuing your use of Our Services, or by checking any authorizations boxes accompanying any links or messages by which you arrived at these Terms, you agree to be bound by these Terms and all other terms, such as Our Terms of Use, as updated from time to time and incorporated hereto by reference. 

We reserve the right to change or modify any of the Terms, the Site, and/or Our Services at any time. If We decide to change Our Terms, We will notify you by revising the date at the top of the Terms and you waive any right to receive specific notice of each such change. Your use of the Site and/or Our Services following the posting of changes or modifications to the Terms will constitute your acceptance of the revised Terms. Therefore, you should review the Terms and applicable policies from time to time to understand the terms and conditions that apply to your use of the Site and/or Services. If you do not agree to the amended terms, you must immediately stop using the Sites and/or Services. 

Please read these Terms carefully to understand Our policies and practices regarding Your information and how We will treat it. If You do not agree with Our policies and practices, You have the choice not to use Our Services. By accessing or using Our Services, You agree to these Terms. These Terms may change from time to time. Your continued use of Our Services after We make changes to the Terms constitutes acceptance of those changes. Please check these Terms periodically for updates.

Definitions

For the purposes of these Terms:

Account means a unique account created for You to access Our Services or parts of Our Services.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Device means any device that can access Our Services such as a computer, a cellphone, or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate Our Services, to provide Our Services on behalf of the Company, to perform services related to Our Services or to assist the Company in analyzing how Our Services are used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use Our Services.

Tracking Technologies refers to any digital feature, such as beacons, tags, and scripts which are used to collect and track information and to improve and analyze Our Services

Usage Data refers to data collected automatically, either generated by the use of Our Services or from Our Services infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using Our Services, or the company, or other legal entity on behalf of which such individual is accessing or using Our Services, as applicable.

Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA“) require Us to inform parents and legal guardians about Our practices for collecting, using, and disclosing personal information from children under the age of thirteen (13) years of age (“Children”). We do not intend to collect Personal Information from Children, and our Services are not designed for Children. Children can access many parts of the Site and its content and use many of its features without providing us with personal information. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including Children) when they visit or use the Site.

To the extent a child may access Our Site or its content, we only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition their participation on the disclosure of more personal information than is reasonably necessary.  

If You are under 13, do not provide any information on Our Services. If We learn We have collected or received Personal Data from a child under 13 without verification or parental consent, We will delete that information. If You believe We might have any information from or about a child under 13, please contact Us through the means of contact listed below.

We do not knowingly share, sell, rent, or transfer Children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, as well as information that does not identify any individual or device. In addition, we may disclose Children’s personal information:

1. To third parties we use to support the internal operations of our Site and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.

2. If we are required to do so by law or legal process, such as complying with any court order or subpoena or responding to any government or regulatory request,

3. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Matrix Global LLC, our customers or others, including to:

• protect the safety of a child;
• protect the safety and security of the Website; or
• enable us to take precautions against liability.

4. To law enforcement agencies or for an investigation related to public safety.

In addition, if Matrix Global LLC is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.

I.          THE KINDS OF INFORMATION WE COLLECT

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You online or offline. We may also use Tracking Technologies or Cookies to collect information or track Your activity while using Our Service. Some of the kinds of information We may collect includes, but is not limited to:

1. Personally identifiable information including, but not limited to: 

         i. First name and last name

         ii. Postal Address

         iii. Email Address

         iv. Country of residence

         v. Signature

         vi. Device IP Address

         vii. Business or commercial account information

         viii. Usage Data

2. Usage Data is collected automatically when using Our Services. Usage Data may include information such as:

         i. Your Device’s Internet Protocol address (e.g. IP address)

         ii. Browser type

         iii. Browser version

         iv. Location data

         v. The pages of Our Service that You visit

         vi. The time and date of Your visit

         vii. The time spent on those pages

         viii. Unique device identifiers

         ix. Other diagnostic data

3. When You access Our Services by or through a mobile device, We may collect certain information automatically, including, but not limited to:

         i. The type of mobile device You use

         ii. Your mobile device unique ID

         iii. The IP address of Your mobile device

         iv. Your mobile operating system

         v. The type of mobile Internet browser You use

         vi. Location data

         vii. Unique device identifiers

         viii. Other diagnostic data.

4. Information that Your browser sends whenever You visit Our Services or when You access Our Services by or through a mobile device.

5. Information through Tracking Technologies and Cookies. We use Cookies and similar Tracking Technologies to track the activity on Our Services and store certain information. The Tracking Technologies We use may include, but is not limited to:

i. Cookies or Browser Cookies. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Services. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Services may use Cookies as further outlined in our Cookie Policy, virginiamonthly.com.

ii. Web Beacons. Certain sections of Our Services and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

iii. Google Analytics. Matrix Global also uses Google Analytics as a tool for tracking and analyzing its web traffic. Google Analytics runs on Our server and uses a combination of first-party cookies and JavaScript code to compile information that is synthesized into reports about page visits, referring sites, user habits, and the like. Google is not provided access to any user information other than IP addresses. Google has created an “Opt-out Browser Add-on” for users who wish to use websites while preventing their data from being accessed or used by Google Analytics. If You want to opt out of the features on Services that rely on Google Analytics, please follow the directions provided by Google here: https://tools.google.com/dlpage/gaoptout/features‍

6. Information about Your online activities over time and across third-party websites or other online services (behavioral tracking). For information on how to opt out of behavioral tracking on this Site, please see Our Cookie Policy, virginiamonthly.com. This behavioral tracking helps Us to improve Our Site and to deliver a better and more personalized service, including by enabling Us to: 

         i. Estimate Our audience size and usage patterns. 

         ii. Store information about Your preferences, allowing Us to customize Our Site according to Your individual interests. 

         iii. Speed up Your searches. 

         iv. Recognize You when You return to Our Site.

7. Information from phone calls, emails, texts, and other electronic messages between You and Our Services and/or Us.

8. Details of transactions You carry out through Our Services and of the fulfillment of Your requests.

9. Information collected from Our IT systems, including:

         i. Automated monitoring of Our Site and other technical systems, such as Our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; 

         ii. Information that You provide by filling in forms on Our Site. This includes information provided at the time of registering to use Our Site, subscribing to Our Services, posting material, or requesting further services. We may also ask You for information when You enter a contest or promotion sponsored by Us, and when You report a problem with Our Site;

         iii. Records and copies of Your correspondence (including email addresses), if You contact Us;

         iv. Your responses to surveys that We might ask You to complete for research purposes;

         v. Details of transactions You carry out through Our Site and of the fulfillment of Your orders. You may be required to provide financial information before placing an order through Our Site; and

         vi. Your search queries on the Site or through Our Services

We do not collect the following kinds of information:

1. Characteristics of protected classifications under California or federal law

2. Biometric information

3. Audio, electronic, visual, thermal, olfactory, or similar information

4. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

II.          LINKS TO OTHER WEBSITES AND THIRD PARTIES

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about You when You use Our Site. The information they collect may be associated with Your Personal Data or they may collect information, including Personal Data, about Your online activities over time and across different websites and other online services. They may use this information to provide You with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly. Our Services may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. 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.

These Terms do not apply to any information collected by any third party (including Our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on Our Services

III.          HOW WE USE AND DISCLOSE YOUR INFORMATION

We use information that We collect about You or that You provide to Us, including any Personal Data:

1. To present Our Services and its contents to You.

2. To provide to Our affiliate publishers and subsidiaries to perform our Services.

3. To provide You with information, products, or services that You request from Us.

4. To fulfill any other purpose for which You provide it.

5. To provide You with notices about Your account.

6. To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including processing Your request or application.

7. To notify You about changes to Our Services or any products or services We offer or provide though it.

8. To allow You to participate in interactive features on Our Services.

9. In any other way We may describe when You provide the information.

10. To contact You about Our own and third-parties’ goods and services that may be of interest to You.

11. To provide products and/or services to You.

         i. For the performance of Our contract with You or to take steps at Your request before entering into a contract

12. To prevent and detect fraud against You or Matrix Global.

         i. For Our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for Us and for You

13. Ensuring business policies are adhered to, e.g. policies covering security and internet use

         i. For Our legitimate interests or those of a third party, i.e., to make sure We are following Our own internal procedures so We can deliver the best service to You

14. Operational reasons, such as improving efficiency, training and quality control

         i. For Our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for You at the best price

15. Ensuring the confidentiality of commercially sensitive information

         i. For Our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information

         ii. To comply with Our legal and regulatory obligations

16. Statistical analysis to help Us manage Our business

         i. For Our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for You at the best price

17. Preventing unauthorized access and modifications to systems

         i. For Our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for Us and for You

         ii. To comply with Our legal and regulatory obligations

18. Updating and enhancing customer records

         i. For the performance of Our contract with You or to take steps at Your request before entering into a contract

         ii. To comply with Our legal and regulatory obligations

         iii. For Our legitimate interests or those of a third party, e.g., making sure that We can keep in touch with Our customers about existing orders and new products

19. Statutory returns

         i. To comply with Our legal and regulatory obligations

         ii. Ensuring safe working practices, staff administration and assessments

         iii. To comply with Our legal and regulatory obligations

         iv. For Our legitimate interests or those of a third party, e.g. to make sure We are following Our own internal procedures and working efficiently so We can deliver the best service to You

20. Marketing Our Services and those of selected third parties to:

         i. existing and former customers;

         ii. third parties who have previously expressed an interest in Our Services;

         iii. third parties with whom We have had no previous dealings.

         iv. To comply with Our legal and regulatory obligations

         v. For Our legitimate interests or those of a third party, e.g. to make sure We are following Our own internal procedures and working efficiently so We can deliver the best service to You

21. External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of Our accounts

         i. For Our legitimate interests or a those of a third party, i.e. to maintain Our accreditations so We can demonstrate We operate at the highest standards

         ii. To comply with Our legal and regulatory obligations

22. For any other purpose with Your consent.

We strive to provide You with choices regarding the Personal Data You provide to Us. We have created mechanisms to provide You with the following control over Your information: 

1. Tracking Technologies and Advertising. You can set Your browser to refuse all or some browser cookies, or to alert You when cookies are being sent. Please consult Your browser’s documentation to learn how. Note that certain portions of Our Services may not operate as intended if You refuse certain cookies.

2. Disclosure of Your Information for Third-Party Advertising. If You do not want Us to share Your Personal Data with unaffiliated or non-agent third parties for promotional purposes, You can opt-out by checking the relevant box located on the form on which We collect Your data. You can also always opt-out by contacting Us using the methods listed below.

3. Targeted Advertising. If You do not want Us to use information that We collect or that You provide to Us to deliver advertisements according to Our advertisers’ target-audience preferences, You can opt-out by contacting Us using the methods listed below.  

We do not control third parties’ collection or use of Your information to serve interest-based advertising. However, these third parties may provide You with ways to choose not to have Your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website. Residents of certain states, may have additional personal information rights and choices which are discussed below.

We may disclose aggregated information about Our users without restriction. We may disclose Personal Data that We collect or You provide as described in these Terms:

1. To Our  affiliates.

2. To contractors, service providers, and other third parties We use to support Our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which We disclose it to them.

3. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Matrix Global’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Matrix Global about Our Services users is among the assets transferred.

4. To third parties to market their products or services to You if You have not opted out of these disclosures. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which We disclose it to them.

5. To fulfill the purpose for which You provide it. For example, when using Our Services, You may contact Us to request information about Matrix Global or Our products and services. In choosing these options, You may provide Us with information that We use to send You the information, evaluate and process Your request or application or provide You with the services You request. 

6. For any other purpose disclosed by Us when You provide the information.

7. With Your consent.

8. We may also use for other purposes and disclose to third parties information that does not constitute personally identifiable information. 

We may also disclose Your Personal Data:

1. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

2. To enforce or apply Our Terms of Use, Terms of Sale, and/or other agreements.

3. If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of Matrix Global, Our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

IV.          PERSONAL DATA WE SOLD OR DISCLOSED FOR A BUSINESS PURPOSE

In the preceding 12 months, We may have sold to one or more third parties the following categories of Personal Data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); and

2. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement).

In the preceding 12 months, We may have disclosed for a business purpose to one or more third parties the following categories of Personal Data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); and

2. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement).

V.          HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep Your Personal Data while You have an account with Us or while We are providing products and/or services to You. Thereafter, We will keep Your Personal Data for as long as is necessary:

1. To respond to any questions, complaints or claims made by You or on Your behalf;

2. To show that We treated You fairly; or

3. To keep records required by law.

We will not retain Your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data.

VI.          SECURITY OF YOUR INFORMATION

We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorized way. We limit access to Your Personal Data to those who have a genuine business need to access it. Those processing Your information will do so only in an authorized manner and are subject to a duty of confidentiality. We follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify You and any applicable regulator of a suspected data security breach where We are legally required to do so. The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

VII.          UPDATING YOUR INFORMATION

You can contact Us using the methods listed below to request access to, correct, or delete any Personal Data that You have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If You delete Your User Contributions from the Website, copies may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service. Residents of certain states may have additional Personal Data rights and choices, some of which are detailed below.

VIII.          CONTACT INFORMATION

To ask questions or make a request under this privacy policy and Our privacy practices, please write to us at Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands or send us an email at matrixglobalnews@gmail.com.

IX.          CALIFORNIA PRIVACY RIGHTS – FOR CONSUMERS IN CALIFORNIA

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of Our Services that are California residents to request certain information regarding Our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact Us using the methods listed above. This section is Our Privacy Notice for California Residents (“Notice”) and applies to visitors, users, and others who reside in the State of California (“Consumers,” or “You/Your”) and use Our Services, as contemplated under the California Consumer Privacy Act of 2018 (“CCPA”)/California Privacy Rights Act of 2020 (“CPRA”). 

We collect information from users, and We use and/or disclose the information for different business purposes. The chart below identifies the Personal Data We may collect and lists the parties with whom We may share this information and for what business purpose.

We may use or disclose the Personal Data We collect for one or more of the purposes listed in the chart above. We will not collect additional categories of Personal Data or use the Personal Data We collected for materially different, unrelated, or incompatible purposes without providing You notice.

In the past 12 months, We may have disclosed Personal Data to third parties for business purposes as set forth in the chart above and as discussed in these Terms.

Access to Specific Information and Data Portability Rights

You have the right to request that We disclose certain information to You about Our collection and use of Your Personal Data over the past 12 months. Once We receive and confirm Your verifiable consumer request (see “Exercising Your Rights” section), We will disclose to You, free of charge:

1. The categories of Personal Data We collected about You;

2. The categories of sources for the Personal Data We collected about You;

3. The categories of sources from which the Personal Data is collected;

4. Our business or commercial purpose for collecting or selling that Personal Data;

5. The categories of third parties with whom We share that Personal Data;

6. The specific pieces of Personal Data We collected about You (also called a data portability request;

7. If We sold or disclosed Your Personal Data for a business purpose, two separate lists disclosing:

          i. Sales, identifying the Personal Data categories that each category of recipient purchased; and

          ii. Disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Under the CCPA/CPRA, We are not required to: 

1. Retain any Personal Data about You that was collected for a single one-time transaction if, in the ordinary course of business, that information about You is not retained; 

2. Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or 

3. Provide the Personal Data to You more than twice in a 12-month period.

Deletion Request Rights

You have the right to request that We delete any of Your Personal Data that We collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request (see “Exercising Your Rights” section), We will delete (and direct Our service providers to delete) Your Personal Data from Our/their records. 

Please be aware that under certain circumstances, the CCPA/CPRA may limit Your exercise of these rights. Such exceptions include if the Personal Data is required to:

1. Complete the transaction for which the Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us; 

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 

3. Debug to identify and repair errors that impair existing intended functionality; 

4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; 

5. Comply with the California Electronic Communications Privacy Act; 

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent; 

7. Enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us; 

8. Comply with an existing legal obligation; or 

9. Otherwise use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information. 

Personal Data Sold or Used for a Business Purpose

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of Your Personal Data. If You exercise Your right to opt-out of the sale or disclosure of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data. To opt-out of the sale or disclosure of Your Personal Data, contact Us using the methods listed above.

When Your Personal Data was sold or used for a business purpose, You have the right to know:

1. The categories of Personal Data about You that We sold and the categories of third parties to whom the Personal Data was sold; and 

2. The categories of Personal Data that We disclosed about You for a business purpose.

Exercising Your Rights

If You wish to exercise Your rights under the CCPA/CPRA, please submit a verifiable consumer request to Us by contacting Us using the methods listed above. 

Only You, or someone legally authorized to act on Your behalf, may make a verifiable consumer request related to Your Personal Data. You may also make a verifiable consumer request on behalf of Your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data or an authorized representative.

2. Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We will consider and process Your request within a reasonable period of time. We cannot respond to Your request or provide You with Personal Data if We cannot verify Your identity or authority to make the request and confirm the Personal Data relates to You.

Making a verifiable consumer request does not require You to create an account with Us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Please be aware that under certain circumstances, the CCPA/CPRA may limit Your exercise of these rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to an additional 45 days), We will inform You of the reason and extension period in writing.

Any disclosures We provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response We provide will also explain any reasons why We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Data that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, We will not:

1. Deny You goods or services;

2. Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

3. Provide You a different level or quality of goods or services; or

4. Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

X.          OTHER STATES’ PRIVACY RIGHTS – FOR US CONSUMERS OUTSIDE CALIFORNIA

Many other states have passed, or are in the process of passing, comprehensive privacy laws. These states have varying levels of protections for Your Personal Data, and the types of rights You, as the consumer, have over Your Personal Data. If You are a consumer in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, You may have additional rights that are not expressly enumerated in these Terms. It is Your responsibility to know these rights and how to exercise them. Matrix Global and its affiliates and subsidiaries will not be liable for Your failure to exercise Your rights under any relevant local, state, or federal law where Matrix Global does not have a duty to act in accordance with those laws.

Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature, processing, and purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. 

To exercise any of these rights, please send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands. To appeal a decision regarding a consumer rights request, please send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands

Nevada provides its residents with a limited right to opt out of certain personal information sales. Residents who wish to exercise this sale opt out rights may send mail to Ora Fiduciary (Cook Islands) Limited Global House, Avarua, Rarotonga, Cook Islands

XI.          EU AND UK PRIVACY RIGHTS – FOR CONSUMERS IN THE EU AND THE UK

The General Data Protection Regulation (GDPR) and UK GDPR require Us to explain the valid legal bases We rely on to process Your Personal Data. As such, We may rely on the following legal bases to process Your Personal Data:

1. Consent. We may process Your Personal Data if You have permitted Us (i.e., consent) to use Your Personal Data for a specific purpose. You can withdraw Your consent at any time.

2. Legitimate Interests. We may process Your Personal Data when We believe it is reasonably necessary to achieve Our legitimate business interests. Those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We may process Your Personal Data for some of the purposes described to:

         i. Send users information about special offers and discounts on Our products and services

         ii. Develop and display personalized and relevant advertising content for Our users

         iii. Analyze how Our Services are used so We can improve them to engage and retain users

         iv. Support Our marketing activities

         v. Diagnose problems and/or prevent fraudulent activities

3. Legal Obligations. We may process Your information where We believe it is necessary to comply with Our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending Our legal rights, or disclosing Your information as evidence in litigation in which We are involved.

4. Vital Interests. We may process Your information where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

Under GDPR, You have the following rights:

1. Right to Access. The right to be provided with a copy of Your Personal Data (the right of access)

2. Right to Rectification. The right to require Us to correct any mistakes in Your Personal Data 

3. Right to be Forgotten. The right to require Us to delete Your Personal Data—in certain situations 

4. Right to Restriction of Processing. The right to require Us to restrict processing of Your Personal Data—in certain circumstances, e.g. if You contest the accuracy of the data 

5. Right to Data Portability. The right to receive the Personal Data You provided to Us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations 

6. Right to Object. The right to object at any time to Your Personal Data being processed for direct marketing (including profiling); in certain other situations to Our continued processing of Your Personal Data, e.g. processing carried out for the purpose of Our legitimate interests. 

7. Right Not to be Subject to Automated Individual Decision-Making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning You or similarly significantly affects You 

In legal terms, We are generally the “data controller” under European data protection laws of the Personal Data described in this privacy notice since We determine the means and/or purposes of Our data processing. This privacy notice does not apply to the Personal Data We process as a “data processor” on behalf of Our customers. In those situations, the customer with whom We provide services and with whom We have entered into a data processing agreement is the “data controller” responsible for Your Personal Data, and We merely process Your Personal Data on their behalf in accordance with Your instructions. To know more about Our customers’ privacy practices, You should read their privacy policies and direct any questions You have to them.

Transferring Your Personal Data Out of the EEA

To deliver services to You, it is sometimes necessary for Us to share Your Personal Data outside the European Economic Area (EEA), e.g.:

1. With Your and Our service providers located outside the EEA;

2. If You are based outside the EEA; or

3. Where there is an international dimension to the services We are providing to You.

If You would like further information, please contact Us.

XII.          CANADIAN PRIVACY RIGHTS – FOR CONSUMERS IN CANADA

We may process Your Personal Data if You have given Us specific permission (i.e., express consent) to use Your Personal Data for a specific purpose or in situations where Your permission can be inferred (i.e., implied consent). You can withdraw Your consent at any time. 

In some exceptional cases, We may be legally permitted under applicable law to process Your information without Your consent, including, for example:

1. If collection is clearly in the interests of an individual and consent cannot be obtained promptly.

2. For investigations and fraud detection, and prevention.

3. For business transactions, provided that certain conditions are met.

4. The collection is necessary to assess, process, or settle an insurance claim if it is contained in a witness statement.

5. Identifying injured, ill, or deceased persons and communicating with next of kin.

6. If We have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.

7. If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information, the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

8. If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

9. If an individual produced it during their employment, business, or profession, the collection is consistent with the purposes for which the information was produced.

10. If the collection is solely for journalistic, artistic, or literary purposes.

11. If the information is publicly available and is specified by the regulations.

We may also use Your information to contact You about Our own and third-parties’ services that may be of interest to You.