PRIVACY NOTICE | EFFECTIVE APRIL 24, 2025

Satschel Privacy Notice

Introduction

This Privacy Policy describes how Satschel, for itself or on behalf of any of its wholly owned subsidiaries collectively known as (“Satschel”, “We”, or “Us”), collects and uses the personal information you provide or that is generated on our websites or mobile applications (the “Site”) or in connection with our services (the “Services”). It also describes options that may be available to you regarding the use of, your access to, and updating or correcting your personal information. Note that this Privacy Policy does not apply to any third-party websites or services, including those you reach through links we have provided on the Site. We encourage you to request and review the privacy policies of any third party prior to disclosing information to such a party.

In connection with the Site, Satschel may collect and process personal information that you provide to us or that pertains to your use of the Site (“Site User Information”). Satschel, whose principal office location is 30 Augusta Canyon Way, Las Vegas NV 89141, USA is the “Data Controller” of “Site User Information” for purposes of European or other applicable law. Separate from the “Site User Information”, Satschel collects and otherwise processes personal information in the course of providing services to users (“Service User Information”), but such processing is performed under the direction of its users.

In the normal course of the Services, we transfer “Site User Information” and “Service User Information” to individuals as directed by users of the Service, and to third parties that help or are necessary for us to provide our service. Transfers to such third parties are further addressed in the service agreements with our clients.

The type of Personal Information we collect and use

Site User Information:

In connection with the operation of the site or providing services, we may collect and use the following Site User Information about you:

Service User Information:

Where you use our Services, we process the following Service User Information on behalf of you:

1. Transaction History
2. Anticipated Transaction Volume
3. Positions
4. Account Statements
5. Information received as part of the AML Screening process:

1. Criminal Background
2. Politically Exposed Person (PEP) Status
3. Global Sanctions (OFAC, UN, HMT, EU, and DFAT)
4. Adverse Media
5. Watchlist (Interpol, Federal and State Government Agencies)

Cookies and Similar Technologies

When you visit our Site, we and our third-party partners, including analytics providers such as Google Analytics, collect information by automated means, such as the use of cookies, web beacons, and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Site and emails. We may process this information to determine how many users have visited particular web pages, viewed particular videos, or opened messages or alerts, and we may also use such information to improve the performance of the Site and to prevent fraud. In some cases, our third-party partners may process information collected by such cookies. Under EU and other laws, if and where applicable, the legal basis for the processing of cookie data necessary for the functioning of the Site is our legitimate interest in providing the Site and our Services; for other cookie data, we process that data with your consent.

As indicated above, we, like many other website operators, currently use Google Analytics to collect and process certain Site usage data. To learn more about Google Analytics and how to opt-out, please visit:

https://policies.google.com/technologies/partner-sites.

Google may assert the right to collect and combine information collected on the Site using its Google Analytics cookie with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps use or share data with the same partners. You may be able to change a web browser’s settings to block and delete cookies when you access the Site through that web browser. However, if you do that, the Site may not work properly; also, we will still receive basic information (such as the last URL visited) when you navigate to the Site.

We do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Site with other people or unaffiliated companies for their direct marketing purposes.

Cookies we use:

We use the following cookies on this Site, as indicated:

Use of your Personal Information

Under European Union (EU) and other law, if and where applicable, the legal basis for the processing of your personal information is:

1. To provide and maintain our Services, including the monitoring of the usage of our Services.
2. To manage your Account: The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.
3. To contact you: through emails, telephone calls, SMS, or other equivalent forms of electronic communication, we provide you with updates related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
4. To protect you: we rely on the use of Personal Data to protect our Services against cybersecurity issues such as spam, phishing and Distributed Denial of Service (DDoS) attacks.
5. To protect us: we are required to comply with all applicable legal and regulatory requirements relevant to our provision of Services.
6. To manage your requests: we attend and manage your requests to us on an on-going basis.
7. For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services and your experience.
8. Marketing and Promotional Communications: We may use your personal information to send you product updates, promotional offers, and marketing communications via email, SMS, or messaging services such as WhatsApp, where you have provided your consent. We may share your contact information with trusted third-party service providers who assist us in delivering these communications. These service providers are not permitted to use your personal data for any purpose other than to provide services on our behalf, and they are contractually obligated to comply with applicable data protection laws. You have the right to opt out of receiving marketing communications at any time. You can do this by:
   1. Following the unsubscribe instructions included in every marketing email we send,
   2. Replying “STOP” to SMS or WhatsApp messages,
   3. Adjusting your communication preferences in your account settings, or
   4. Contacting us directly at Privacy@Satschel.com

We respect your choices and will promptly honor your opt-out requests.

Google User Data

If you choose to sign in to Liquidity with your Google account, we receive basic profile information from Google: your name, email address, profile picture and Google account identifier. We do not request access to any other Google data, such as Gmail, Contacts, Drive or Calendar.

We use this information only to create your account, sign you in, and communicate with you about your account. It is stored with your other account information in our Google Cloud and AWS infrastructure in the United States and retained as described in "Retention of your Personal Information".

We do not sell Google user data or use it for advertising. We share it only as described in "How we share your Personal Information", such as with service providers that help us operate the Services or when required by law.

You can remove Liquidity's access to your Google account at any time at https://myaccount.google.com/permissions, and you can ask us to delete your data by contacting us as described in "Contact Us".

Liquidity's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

How we share your Personal Information

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We may share personal information with third parties who perform services for us or on our behalf, and we may share Site User Information and Service User Information with third-party distributors and other business partners to enable them to provide you with Satschel Services. These third parties are not authorized by Satschel to use or disclose your personal information except as necessary to perform services to or on behalf of Satschel or comply with legal requirements, and they are subject to confidentiality and non-disclosure obligations in our agreements with them to protect your personal information.

Except where disclosure of your personal information is required by law or requested by you, we will generally require any third party which receives, or has access to, your personal information to protect it and to use it only to carry out the services they are performing for you or for us unless otherwise required or permitted by law.

If you are located in the EU, the following also applies:

We have concluded data processing agreements with each relevant service provider in accordance with the EU General Data Protection Regulation. Beyond that, we only share or disclose your personal information to the extent required to provide the Services or to sell or transfer the relevant Satschel business or assets, either on basis of our legitimate interests or with your prior express consent.

You should note that you are not obliged to give your personal information to us. If you choose not to do so, we may not be able to provide our services, or your access to our services may be limited.

We may share your personal information in the following situations:

1. Receiving and Sending Text Messages: We use Twilio's services for the purpose of receiving and sending text messaging from/to you. For more information about Twilio's Terms of Service and Messaging Policy, please visit the following links: Terms of Service and Messaging Policy.
   1. Terms of Service: https://www.twilio.com/legal/tos
   2. Messaging Policy: https://www.twilio.com/legal/messaging-policy
2. Anti-bot Service: We use the hCaptcha anti-bot service (hereinafter "hCaptcha") on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation ("IMI"). hCaptcha is used to check whether the data entered on our website (such as on a login page or contact form) has been entered by a human or by an automated program. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). The data collected during the analysis will be forwarded to IMI. hCaptcha analysis in the "invisible mode" may take place completely in the background. Website or app visitors are not advised that such an analysis is taking place if the user is not shown a challenge. Data processing is based on Art. 6(1)(f) of the GDPR (DSGVO): the website or mobile app operator has a legitimate interest in protecting its site from abusive automated crawling and spam. IMI acts as a "data processor" acting on behalf of its customers as defined under the GDPR, and a "service provider" for the purposes of the California Consumer Privacy Act (CCPA). For more information about hCaptcha and IMI's Terms of Use and Privacy Policy, please visit the following links: Privacy Policy and Terms of Service.
   1. Terms of Use: https://hcaptcha.com/terms
   2. Privacy Policy: https://hcaptcha.com/privacy/
3. For Service Monitoring: We may share your personal information with Service Providers to monitor and analyze the use of our Services.
4. For Fraud Prevention: In preventing fraud, Personal Data will be furnished to third-party service providers for Identity Verification, Criminal Background Checks, and Fraud Prevention services, etc.
5. For AML Screening: To minimize the risks associated with money laundering and other illicit activities, Personal Data will be furnished to third-party service providers to screen for information related to Criminal Background, Politically Exposed Person (PEP) Status, Global Sanctions (OFAC, UN, HMT, EU, and DFAT), Adverse Media, Watchlist (Interpol, Federal and State Government Agencies), etc.
6. For Business Transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Satschel’s assets, financing, or acquisition of all or a portion of our business to another company. To the fullest extent permissible under applicable law, Satschel reserves the right to transfer any personal information (i.e., including both Site User Information and Service User Information) in the event that Satschel sells or transfers all or a portion of the Satschel business or assets (including in the event of a reorganization, dissolution or liquidation).
7. 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.
8. With Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
9. With Regulators and Law Enforcement: We may share your personal information with the appropriate regulators whenever necessary; any financial dispute resolution scheme to which we subscribe. This includes law enforcement bodies; regulatory agencies; courts; arbitration bodies; and dispute resolution schemes. This may be both in the jurisdiction where we incorporate and internationally, as may be required by law. In addition, we may share your personal information as required by law, such as in response to a subpoena or other legal process, to establish or exercise our legal rights, to defend against claims, or to protect the safety or security of the public or of users of this Site or our Services, investigate fraud, or respond to a government request.
10. With other Users: When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

Where we store your Personal Information, how we may transfer your Personal Information

This Site is operated from, and Site User Information and Service User Information is stored in the United States of America (USA). We store Site User Information and Service User Information in our Google and AWS Cloud infrastructure located in the United States of America (USA).

Your information, including Personal Information, is processed at Satschel’s operating offices and in any other places 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 the jurisdiction where you are residing. Further, the data protection laws by which Satschel complies may differ from those in your residing jurisdiction.

Your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of Personal Information.

Retention of your Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our regulatory and legal obligations (for example, if we are required to retain your personal information to comply with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing Regulations), resolve disputes, and enforce our legal agreements and policies.

We will also retain Site Usage Information for internal analysis purposes. Site Usage Information is generally retained for a shorter period of time, except when this information is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this information for longer time periods.

We maintain Site User Information and Service User Information for as long as needed for the business purposes for which such information is collected, and in keeping with our record retention policies. In general, the Personal Information relating to you is held for at least a period of five years as required by the regulators after we cease providing you with our Services.

How your Personal Information is protected

Satschel maintains administrative, technical, and physical safeguards (including technical and organizational measures) designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

We require that our service providers implement and maintain appropriate security practices and procedures. Nevertheless, please be aware that Internet transmissions are never completely private or secure. If you have any questions about the security of your personal information, you can contact us at Privacy@Satschel.com

Access, accuracy, and correction of your Personal Information

Certain jurisdictions impose specific legal requirements and data subject rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete the personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. When you make a request, we may require that you provide information and follow procedures so that we can validate a request you make before responding to it. We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.

For California Residents (CCPA & CPRA Notice):

If you are a California resident, you may have certain rights in relation to our processing of Site User Information as to which we are a “business” under the California Consumer Privacy Act (“CCPA”) as amended and expanded by the California Privacy Rights Act (CPRA). Note that we do not “sell” or “share” personal information as those terms are defined  under CCPA/CPRA.  Under California law, you may have the following rights with respect to your personal information:

1. The right to request more information about our data collection and sales practices in connection with your personal information.
2. The right to request a copy of the specific personal information collected about you during the 12 months before your request (together with the above, a “personal information request”). You may only make a personal information request twice in a 12-month period, and we will respond within 45 days of receiving a personal information request.
3. The right to correct inaccurate personal information that we maintain about you.
4. The right to delete personal information we have collected from you, subject to certain exceptions.
5. The right to limit the use and disclosure of sensitive personal information, if applicable.
6. The right to opt out of the sale or sharing of your personal information (we do not currently sell or share personal information).
7. The right to non-discrimination for exercising your privacy rights under CCPA/CPRA.

For European Economic Area (EEA) Data Subjects:

If you are located in the EEA you have certain rights in relation to our processing of Site User Information and Registration Information as to which we are a “controller” under the EU General Data Protection Regulation (“GDPR”), as follows:

1. Right to Information: We will provide you with information about how we process your personal information. This Privacy Policy is designed in part to fulfill this obligation.
2. Right to Access: You may request that we confirm whether we process personal information concerning you, and if we do process such information, to give you access to such information and more detailed information about the associated processing activity.
3. Right to Data Portability: If personal information processing is carried out by automated means and the legal basis for the processing activity is consent or performance of a contract, you may be entitled to request that we provide you with a subset of your personal information in a structured, commonly used, and machine-readable format. In certain circumstances, you may also ask us to send the subset of your personal information directly to another data controller (e.g., another company).
4. Right to Rectification: We seek to ensure that the personal information we are processing is accurate and up-to-date. If you discover that the personal information, we process about you is inaccurate or incomplete, you may ask us to rectify or complete the personal information.
5. Right to Erasure: You may request that we delete your personal information in the following situations: 
   1. the processing is based on your consent and this consent is withdrawn (and there is no other legal basis for the processing);
   2. you object to the processing and there are no overriding legitimate interests for continuing the processing;
   3. the personal information was unlawfully processed; or
   4. the personal information has to be erased in order to comply with a legal obligation.
   5. The right of erasure does not apply if further retention of the personal information in question is necessary for compliance with legal or regulatory obligations (e.g., bookkeeping obligations), or for the establishment, exercise, or defense of legal claims.
6. Right to Restriction: You may request that we (temporarily) restrict the processing of your personal information in certain situations – e.g., if you contest the accuracy of your personal information which we process, or you are of the opinion that we do not have a sufficient legitimate interest for a processing activity.
7. Right to Objection: In certain circumstances (e.g., where the legal basis for processing is a legitimate interest or if we are performing direct marketing), you may object to continued processing for those purposes. If you do so, we will re-evaluate our legitimate business interests and your data protection interests. We will only continue the processing activity if (i) there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or (ii) the processing is necessary to establish, enforce or defend legal claims.
8. Right to Lodge a Complaint: We prefer to resolve any data protection concerns directly with you. However, if you are of the opinion that we do not comply with the data protection obligations set forth in the GDPR, you have the right to submit a complaint with a supervisory authority in the EEA country where you reside, work, or suspect an infringement has occurred.

For additional information from the European Commission concerning data protection and your rights, see:

https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

It is our policy and intention to comply with all applicable legal requirements in a given jurisdiction with respect to privacy and data protection. If you would like to assert any legal rights as a data subject or have questions concerning our processing activities, please contact us at Privacy@Satschel.com. Note that, to process certain requests, we will need to collect information from you so that we can verify your identity.

For UK Residents (UK GDPR Notice):

If you are located in the United Kingdom, your personal information is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Under these laws, you are entitled to certain rights regarding your personal data, including:

1. The right to be informed – You have the right to be informed about the collection and use of your personal data, including the purposes of processing, retention periods, and who it will be shared with.
2. The right of access – You have the right to request a copy of the personal data we hold about you and to obtain information about how it is processed.
3. The right to rectification – If your personal data is inaccurate or incomplete, you have the right to request that it be corrected or completed.
4. The right to erasure ("the right to be forgotten") – You may request the deletion of your personal data where there is no lawful reason for us to continue processing it.
5. The right to restrict processing – You have the right to request the restriction or suppression of your personal data in certain circumstances (e.g., when you contest its accuracy or object to its processing).
6. The right to data portability – You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transfer it to another controller where technically feasible.
7. The right to object – You have the right to object to the processing of your personal data in certain cases, such as when it is processed for direct marketing purposes or on the basis of legitimate interests.
8. RIGHTS RELATED TO AUTOMATED DECISION-MAKING AND PROFILING – YOU HAVE THE RIGHT NOT TO BE SUBJECT TO A DECISION BASED SOLELY ON AUTOMATED PROCESSING, INCLUDING PROFILING, WHICH PRODUCES LEGAL OR SIMILARLY SIGNIFICANT EFFECTS ON YOU.

Children's Privacy

This Site and all Services are intended for adults. Accordingly, we do not knowingly collect information from any person under the age of eighteen.

Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices as it or they relate to the platform, please contact us at Privacy@Satschel.com. If you would like to request that we update or correct any information that you have provided to us or have a complaint about how your personal information has been used, please contact us in the first instance. If we cannot resolve your complaint to your satisfaction, you may complain to the competent authority who may investigate your complaint further.

Privacy Policy Updates

We may update this Privacy Policy from time to time and without prior notice at our sole and absolute discretion of us. We will notify you of any changes by email. You are advised to review the updated Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted. We encourage you to review this Privacy Policy periodically, especially if you don’t visit the Site regularly.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "Last updated" date at the bottom of this Privacy Policy.

Links to other Websites

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.