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Privacy Policy

Last Updated: January 7, 2025

Important: CAVALRY IT CONSULTING LLC is committed to protecting your privacy. We do NOT store your private keys, recovery phrases, or have access to your cryptocurrency. This Privacy Policy explains how we collect, use, and protect your personal information in compliance with GDPR and CCPA regulations.

1. Data Controller

Data Controller: CAVALRY IT CONSULTING LLC
Address: 19371 WEYMOUTH LANE, HUNTINGTON BEACH, CA 92646, United States
Email: info@cavalry.it.com
Phone: +1 (714) 925-5420

2. Information We Collect

2.1 Information You Provide

Data Type	Purpose	Legal Basis (GDPR)
Name and Shipping Address	Beta program fulfillment (if selected)	Contract Performance / Consent
Email Address	Beta application, support, updates	Consent, Legitimate Interest
Phone Number (optional)	Customer support, delivery notifications	Consent
Payment Information	Transaction processing	Contract Performance

2.2 Automatically Collected Information

Data Type	Purpose	Legal Basis (GDPR)
IP Address	Security, fraud prevention, analytics	Legitimate Interest
Device Information	App compatibility, troubleshooting	Legitimate Interest
Usage Data	Service improvement, analytics	Legitimate Interest
Cookies (see Cookie Policy)	Website functionality, analytics	Consent

2.3 Information We DO NOT Collect

We explicitly DO NOT collect, store, or have access to:

Your private keys or seed phrases
Your cryptocurrency wallet addresses
Your transaction history or blockchain activity
Your PIN codes or authentication credentials
Your cryptocurrency balances or holdings

3. How We Use Your Information

3.1 Primary Uses

Beta Program: Process applications and ship SecureCard Pro to selected beta testers
Customer Support: Respond to inquiries, provide technical assistance, and resolve issues
Product Updates: Send firmware updates, security notifications, and important product information
Legal Compliance: Comply with applicable laws, regulations, and legal processes

3.2 Secondary Uses (with consent)

Marketing Communications: Send promotional emails about new products and features (opt-out available)
Service Improvement: Analyze usage patterns to improve our app and services

4. Legal Bases for Processing (GDPR)

We process your personal data based on the following legal grounds:

Consent: Processing based on your explicit consent (beta program application, marketing communications, optional data collection, cookies)
Legitimate Interest: Processing necessary for our legitimate business interests (fraud prevention, security, service improvement) that do not override your rights
Legal Obligation: Processing required to comply with legal obligations (tax reporting, law enforcement requests)

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We share limited data with trusted third parties who assist us in operating our business:

Service Provider	Purpose	Data Shared
Payment Processors	Process credit card transactions	Payment information, billing address
Shipping Carriers	Deliver products	Name, shipping address, phone number
Email Service Providers	Send transactional and marketing emails	Email address, name
Cloud Hosting	Store and process data securely	Account information, order history
Analytics Providers	Website and app analytics	Usage data, IP address (anonymized)

All third-party providers are contractually obligated to protect your data and use it only for specified purposes.

5.2 We Do NOT Sell Your Data

We do NOT sell personal data to third parties. We do NOT share data for advertising purposes.

5.3 Legal Disclosures

We may disclose your information when required by law:

In response to valid legal requests (subpoenas, court orders, warrants)
To protect our rights, property, or safety
To prevent fraud or illegal activities
In connection with business transfers (mergers, acquisitions)

6. International Data Transfers

Latitude Park is based in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States.

6.1 EU-US Data Transfers

For transfers from the European Union to the United States, we rely on:

Standard Contractual Clauses (SCCs): We implement EU Commission-approved Standard Contractual Clauses with our service providers
Adequacy Decisions: Where applicable, we rely on European Commission adequacy decisions
Additional Safeguards: Encryption, access controls, and regular security audits

6.2 Other International Transfers

For transfers to other countries, we ensure appropriate safeguards are in place through Standard Contractual Clauses or other legally recognized mechanisms.

7. Data Retention

We retain your personal data only as long as necessary for the purposes stated in this Privacy Policy or as required by law.

Data Category	Retention Period	Reason
Beta Application Data	3 years	Program management, warranty claims
Customer Support Records	3 years	Service quality, warranty claims
Marketing Consent	Until withdrawal	Marketing communications
Analytics Data	26 months	Service improvement
Account Information	Until deletion request	Account management

General Principle: We retain data only as long as necessary for stated purposes or as required by law. After retention periods expire, data is securely deleted or anonymized.

8. Your Rights Under GDPR

If you are in the European Union, you have the following rights:

8.1 Right to Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data and request a copy of your data.

8.2 Right to Rectification (Article 16)

You have the right to request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure / "Right to be Forgotten" (Article 17)

You have the right to request deletion of your personal data when:

Data is no longer necessary for the purposes collected
You withdraw consent and there is no other legal basis for processing
You object to processing and there are no overriding legitimate grounds
Data has been unlawfully processed
Data must be erased for legal compliance

8.4 Right to Restriction of Processing (Article 18)

You have the right to request restriction of processing when:

You contest the accuracy of personal data
Processing is unlawful but you oppose erasure
We no longer need the data but you need it for legal claims
You have objected to processing pending verification

8.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

8.6 Right to Object (Article 21)

You have the right to object to processing based on legitimate interests or for direct marketing purposes at any time.

8.7 Right to Withdraw Consent (Article 7)

Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

8.8 Right to Lodge a Complaint (Article 77)

You have the right to lodge a complaint with your local supervisory authority if you believe our processing violates GDPR.

To exercise your GDPR rights, contact us at: info@cavalry.it.com

We will respond to requests within 30 days as required by GDPR.

9. Your Rights Under CCPA (California Residents)

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

9.1 Right to Know

You have the right to request:

Categories of personal information collected
Specific pieces of personal information collected
Categories of sources from which information was collected
Business or commercial purpose for collecting information
Categories of third parties with whom we share information

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

9.3 Right to Opt-Out of Sale

We do NOT sell personal information. Therefore, there is no need to opt-out of sale.

9.4 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. You will not receive different prices or services for exercising your rights.

9.5 Authorized Agent

You may designate an authorized agent to make requests on your behalf. The agent must provide written authorization.

To exercise your CCPA rights, contact us at: info@cavalry.it.com or call +1 (714) 925-5420

We will verify your identity before processing requests and respond within 45 days as required by CCPA.

10. Data Security

We implement industry-standard security measures to protect your personal information:

10.1 Technical Safeguards

Encryption: All data transmitted over the internet is encrypted using TLS 1.3
Secure Storage: Personal data is stored on encrypted servers with restricted access
Access Controls: Only authorized personnel have access to personal data on a need-to-know basis
Regular Audits: We conduct regular security audits and vulnerability assessments
Incident Response: We have procedures in place to respond to data breaches

10.2 Physical Safeguards

Secure data centers with 24/7 monitoring
Restricted physical access to servers and equipment
Video surveillance and access logging

10.3 Administrative Safeguards

Employee training on data protection and privacy
Confidentiality agreements with all personnel
Regular policy reviews and updates

Important: While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

11. Children's Privacy

SecureCard Pro is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

If you believe we have collected information from a child, please contact us at info@cavalry.it.com.

12. Marketing Communications

We may send you marketing emails about new products, features, and promotions if you have consented to receive such communications.

12.1 Opt-Out

You can opt-out of marketing communications at any time by:

Clicking the "unsubscribe" link in any marketing email
Contacting us at info@cavalry.it.com
Updating your preferences in your account settings

Note: Even if you opt-out of marketing communications, we will still send you transactional emails related to your orders and account.

13. Cookies and Tracking

We use cookies and similar tracking technologies on our website. Please see our Cookie Policy for detailed information about the cookies we use and how to manage them.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

Posting the updated policy on our website with a new "Last Updated" date
Sending an email notification to registered users
Displaying a prominent notice in our mobile app

Your continued use of SecureCard Pro after changes constitutes acceptance of the updated Privacy Policy.

15. Contact Us

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

CAVALRY IT CONSULTING LLC
Privacy Department
19371 WEYMOUTH LANE
HUNTINGTON BEACH, CA 92646
United States

Email: info@cavalry.it.com
Phone: +1 (714) 925-5420

EU Representative (for GDPR inquiries):
Email: info@cavalry.it.com

16. Supervisory Authorities

If you are in the European Union and believe we have violated your data protection rights, you may lodge a complaint with your local supervisory authority:

Ireland: Data Protection Commission - www.dataprotection.ie
UK: Information Commissioner's Office - ico.org.uk
Germany: Bundesbeauftragter für den Datenschutz - www.bfdi.bund.de
France: Commission Nationale de l'Informatique et des Libertés - www.cnil.fr

For a complete list of EU supervisory authorities, visit: https://edpb.europa.eu/about-edpb/about-edpb/members_en