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Acceptance of the Privacy Policy

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use our services and informs you about your privacy rights and how the law protects you. By using our services, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Mandioca LLC.
• 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.
• Account means a unique account created for you to access our service or parts of our service.
• Website refers to Mandioca LLC accessible from [mandioca.global]
• Service refers to  that specializes in trade financing and technology-driven solutions for various industries.
• Country refers to the United States.
• 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 the service, to provide the service on behalf of the company, to perform services related to the service, or to assist the company in analyzing how the service is 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 the service.
• Personal Data is any information that relates to an identified or identifiable individual.
• 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 the service such as a computer, a cell phone, or a digital tablet.
• Usage Data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

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. Personally identifiable information may LLC include, but is not limited to:

• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Date of Birth
• Legal identity document
• If required, your Social Security Number or Taxpayer Identification Number
• Proof of Address in some cases
• Usage Data

We use automated services to screen customers when making crypto purchases or sales to comply with "know your customer" and other government rules and regulations.

Usage Data

Usage Data is collected automatically when using the service. Usage Data may include information such as your device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data. We may also collect information that your browser sends whenever you visit our service or when you access the service by or through a mobile device.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. 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 service. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our service, including monitoring the usage of our service.
• To manage your account: to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the service.
• To contact you: To contact you by email, US Mail, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.

Sharing Your Personal Data

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our service, to contact you.
• For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• With Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
• With Other Users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures, and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you, and view your profile.

Retention of Your Personal Data

The Company will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.

Transfer of Your Personal Data

Your information, including personal data, is processed at the company’s operating offices and in any other place where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. The company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Your Personal Data

We may disclose your personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of the company.
• Prevent or investigate possible wrongdoing in connection with the service.
• Protect the personal safety of users of the service or the public.
• Protect against legal liability.

Security of Your Personal Data

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.

General Data Protection Regulation (GDPR)

The Gramm-Leach-Bliley Act (the "GLBA") is also known as the Financial Modernization Act of 1999. It is a United States federal law, enforced by the Federal Trade Commission ("FTC") that requires financial institutions to explain how they share and protect their customers’ private information. To be GLBA compliant, financial institutions must communicate to their customers how they share the customers’ sensitive data, inform customers of their right to opt-out if they prefer that their information not be shared with third parties, and apply specific protections to customers’ private data in accordance with a written information security plan created by the institution.

Children’s Privacy

Our service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13.

Clean Desk Policy

To ensure the security and confidentiality of Personal Identifiable Information (PII), all employees must adhere to the following clean desk standards:

• Clear Desk: At the end of each workday, all documents containing PII must be stored in locked drawers or cabinets. No PII should be left visible on desks.
• Secure Disposal: Any documents containing PII that are no longer needed must be shredded using a cross-cut shredder.
• Screen Security: Computer screens must be locked when unattended to prevent unauthorized access to PII.

Email Use Policy

To protect the integrity and confidentiality of PII communicated via email, the following email use standards are enforced:

• Company Email: Only company-issued email accounts should be used for sending and receiving PII.
• Encryption: PII sent via email must be encrypted. Tools and protocols for email encryption must be used as instructed by IT.
• Phishing Awareness: Employees must complete regular training on identifying and avoiding phishing attempts. Suspicious emails should be reported to IT immediately.

Remote Networking Policy

When accessing company systems remotely, employees must follow these standards to protect PII:

• VPN Use: A secure Virtual Private Network (VPN) must be used for all remote connections to company systems.
• Device Security: Personal devices used for remote work must have up-to-date antivirus software and comply with the company’s security policies.
• Confidential Workspaces: Remote work should be conducted in private, secure environments to prevent unauthorized access to PII.

Password Policy

To prevent unauthorized access to systems containing PII, the following password standards are in place:

• Strong Passwords: Passwords must be a minimum of 12 characters and include a mix of upper and lower case letters, numbers, and special characters.
• Regular Changes: Passwords must be changed every 90 days. Passwords should not be reused within a 12-month period.
• Multi-Factor Authentication: Multi-factor authentication (MFA) must be enabled for access to systems containing PII.

Records Management Policy

To ensure proper handling of records containing PII, the following standards are enforced:

• Retention: Records containing PII must be retained only as long as necessary to meet legal, regulatory, or operational requirements.
• Secure Storage: Physical records containing PII must be stored in locked, secure locations. Electronic records must be stored in secure, access-controlled systems.
• Disposal: PII records that are no longer needed must be disposed of securely, using cross-cut shredding for physical documents and secure deletion methods for electronic records.

Gramm-Leach-Bliley Act (GLBA) Compliance

As required by the GLBA, we implement the following measures to protect PII:

• Information Security Plan: We have a written information security plan that outlines how we protect PII. This plan is reviewed and updated regularly.
• Client Communication: We inform clients about how their PII is collected, used, and shared. Clients are given the option to opt-out of sharing their PII with third parties.
• Data Protection: We apply specific protections to clients’ PII, including encryption, access controls, and secure disposal methods.

If you have any questions or concerns about our privacy practices, please contact us at:

Email: info@mandioca.global
Website: [mandioca.global]

Contact Information:

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If you have any questions or wish to revoke your consent, please contact us at:

• Email: info@mandioca.global
• Website: [mandioca.global]

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