Last Updated: July 2025
Effective Date: July 2025

1. Introduction

ExtrovertVIX Trading ("we," "us," or "our") operates the Golden Spikes mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.

By using our App, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the App.

2. Information We Collect

2.1 Personal Information You Provide

When you register for an account or use our services, we may collect:

• Account Information: Name, email address, phone number
• Profile Information: Trading preferences, market interests, notification settings
• Payment Information: Payment method details, transaction references (we do not store complete payment card information)
• Communication Data: Messages sent through our support channels, live chat interactions
• Verification Documents: Payment proof screenshots and references for subscription verification

2.2 Automatically Collected Information

When you use our App, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers
• Usage Data: App interactions, feature usage, session duration
• Technical Data: IP address, browser type, time zone settings
• Analytics Data: App performance metrics, crash reports, user engagement statistics

2.3 Firebase and Third-Party Services

Our App uses Firebase services and other third-party tools that may collect information:

• Firebase Authentication: For secure user login and account management
• Firebase Cloud Messaging: For push notifications about trading signals
• Firebase Analytics: For app usage analytics and performance monitoring
• Firebase Firestore: For secure data storage and synchronization
• Tawk.to Live Chat: For customer support communications
• Email Service Providers: For account verification and notifications

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Provision

• Provide trading signals and market analysis
• Manage user accounts and subscriptions
• Process payments and verify subscription status
• Send push notifications about trading opportunities
• Provide customer support and respond to inquiries

3.2 App Improvement

• Analyze app usage to improve features and user experience
• Monitor app performance and fix technical issues
• Develop new features based on user behavior and feedback
• Conduct internal research and analytics

3.3 Communication

• Send important account notifications and service updates
• Provide subscription renewal reminders and payment confirmations
• Share trading education content and market insights (with consent)
• Respond to support requests and provide customer service

3.4 Legal and Security

• Comply with legal obligations and regulatory requirements
• Protect against fraud, abuse, and security threats
• Enforce our Terms of Service and other policies
• Resolve disputes and troubleshoot problems

4. Information Sharing and Disclosure

4.1 We Do Not Sell Personal Information

We do not sell, trade, or rent your personal information to third parties for marketing purposes.

4.2 Service Providers

We may share information with trusted third-party service providers who assist us in:

• Payment processing and subscription management
• Email delivery and communication services
• Analytics and app performance monitoring
• Customer support and live chat services
• Cloud storage and data backup services

4.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes, court orders, or government requests
• Protect our rights, property, or safety, or that of our users
• Investigate potential violations of our Terms of Service
• Prevent fraud or other illegal activities

4.4 Business Transfers

In the event of a merger, acquisition, or sale of our business, user information may be transferred as part of the transaction, subject to appropriate confidentiality protections.

5. Data Security

5.1 Security Measures

We implement appropriate technical and organizational security measures to protect your personal information:

• Encryption: Data transmission is encrypted using industry-standard protocols
• Firebase Security: We leverage Google Firebase's enterprise-grade security infrastructure
• Access Controls: Limited access to personal information on a need-to-know basis
• Regular Monitoring: Continuous monitoring for security threats and vulnerabilities
• Secure Storage: Personal information is stored in secure, access-controlled environments

5.2 Data Breach Response

In the unlikely event of a data breach, we will:

• Immediately investigate and contain the breach
• Notify affected users within 72 hours if required by law
• Implement additional security measures to prevent future incidents
• Cooperate with relevant authorities as necessary

6. Your Privacy Rights

6.1 Access and Control

You have the right to:

• Access: Request a copy of the personal information we hold about you
• Update: Modify or correct your account information through the App
• Delete: Request deletion of your account and associated personal data
• Export: Request a portable copy of your data in a structured format

6.2 Communication Preferences

You can control communications by:

• Adjusting notification settings within the App
• Unsubscribing from marketing emails using the provided links
• Contacting us directly to update your communication preferences

6.3 Account Deletion

You can delete your account at any time through the App settings. Upon account deletion:

• Personal information will be permanently removed from our active systems
• Some information may be retained for legal or legitimate business purposes
• Anonymized data may be retained for analytics and service improvement

7. Data Retention

7.1 Retention Periods

We retain personal information for different periods based on the type of data:

• Account Information: Retained while your account is active and for up to 2 years after deletion
• Transaction Records: Retained for up to 7 years for tax and regulatory compliance
• Communication Logs: Retained for up to 3 years for customer service quality and legal purposes
• Analytics Data: Anonymized and retained indefinitely for service improvement

7.2 Automatic Deletion

We automatically delete or anonymize certain data:

• Inactive accounts after 3 years of no activity
• Temporary files and cache data after 30 days
• Failed login attempts and security logs after 90 days

8. International Data Transfers

8.1 Global Operations

As we serve users globally, your information may be transferred to and processed in countries other than your own, including:

• United States (Firebase/Google Cloud infrastructure)
• European Union (backup and redundancy systems)
• Other countries where our service providers operate

8.2 Transfer Safeguards

When transferring data internationally, we ensure appropriate safeguards through:

• Standard contractual clauses approved by relevant data protection authorities
• Adequacy decisions by the European Commission where applicable
• Certification schemes and codes of conduct recognized by data protection authorities

9. Children's Privacy

9.1 Age Restrictions

Our App is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. Trading involves financial risk and requires adult understanding and legal capacity.

9.2 Discovery of Children's Data

If we discover that we have collected personal information from a child under 18, we will:

• Immediately delete the information from our systems
• Terminate the account if applicable
• Notify the parents or guardians if required by law

10. Third-Party Links and Services

10.1 External Links

Our App may contain links to third-party websites, including:

• Trading platforms and brokers
• Educational resources and market analysis sites
• Social media platforms (Telegram, Facebook)
• Payment processors and financial services

10.2 Third-Party Responsibility

We are not responsible for the privacy practices of third-party websites or services. We encourage you to read the privacy policies of any third-party services you access through our App.

11. California Privacy Rights (CCPA)

11.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request information about the categories and specific pieces of personal information we collect
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: Opt-out of the sale of personal information (note: we do not sell personal information)
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

11.2 Exercising Rights

To exercise these rights, contact us at privacy@extrovertvix.com with proof of your identity and California residency.

12. European Privacy Rights (GDPR)

12.1 Legal Basis

If you are located in the European Economic Area (EEA), our legal basis for processing your personal information includes:

• Consent: For marketing communications and non-essential cookies
• Contract Performance: To provide our trading signal services
• Legitimate Interests: For analytics, security, and service improvement
• Legal Compliance: To meet regulatory and tax requirements

12.2 GDPR Rights

Under GDPR, you have the right to:

• Access, rectify, or erase your personal data
• Restrict or object to processing
• Data portability
• Withdraw consent at any time
• Lodge a complaint with your local data protection authority

13. Updates to This Privacy Policy

13.1 Policy Changes

We may update this Privacy Policy from time to time to reflect:

• Changes in our data practices
• New features or services
• Legal or regulatory requirements
• Industry best practices

13.2 Notification of Changes

When we update this Privacy Policy, we will:

• Post the updated policy in the App and on our website
• Update the "Last Updated" date at the top of this policy
• Notify users of material changes through email or in-app notifications
• Obtain consent for changes that materially affect how we use personal information

14. Contact Information

14.1 Privacy Questions

If you have questions about this Privacy Policy or our data practices, please contact us:

Email: privacy@extrovertvix.com
Support Email: pipsgenius@extrovertvix.com
Website: https://www.extrovertvix.com
Address: ExtrovertVIX Trading, Zimbabwe

14.2 Data Protection Officer

For GDPR-related inquiries, you may contact our Data Protection Officer: Email: dpo@extrovertvix.com

14.3 Response Time

We aim to respond to all privacy-related inquiries within 30 days. For urgent matters, please indicate the urgency in your communication.

15. Effective Date and Acceptance

This Privacy Policy is effective as of the date listed at the top of this document. By using the Golden Spikes App, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use our App or services.

This Privacy Policy is designed to comply with applicable data protection laws, including GDPR, CCPA, and other regional privacy regulations. It will be regularly reviewed and updated to ensure continued compliance and protection of user privacy.