Privacy Notice

iTradeNetwork is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.

This Privacy Notice applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”). 

1. Collection of Personal Data. We collect three types of Personal Data from you:

• Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; place or customize orders; or sign up for an account or other services.
• Data collected automatically and through Cookies. We may automatically collect information or inferences about you; such as through cookies, pixels, tags, scripts, and similar technologies (collectively, “Cookies”), when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information. For more information about Cookies, please see our Cookies Policy below.
• From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
• From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.

In some cases, the collection and processing (see Section 2 below) of Personal Data is required for you to receive certain products or services. We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and have obtained any necessary consent for the information to be used in accordance with this Privacy Notice. If you believe that your Personal Data has been provided to us improperly or want to exercise your rights relating to your Personal Data, please contact us by sending an email to privacy@itradenetwork.com. 

Personal Data does not include information that is anonymized or aggregated such that you cannot be identified from it. 

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and have obtained any necessary consent for the information to be used in accordance with this Privacy Notice. If you believe that your Personal Data has been provided to us improperly or want to exercise your rights relating to your Personal Data, please contact us by sending an email to privacy@itradenetwork.com.

2. Types of Personal Data We Collect. We may collect the following types of Personal Data about you.

• Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
• Records about you, such as signatures ;the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
• Demographic information, such as age (including birthdates) and gender.
• Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. 
• Geolocation data, such as your location as derived from your IP address.
• Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
• Professional or employment-related information (for Business Contacts), such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
• Education information (for Business Contacts).
• sensitive personal information, including the following:
  
  • Account log-in information.
  • Precise geolocation.
  • Content of mail, email, and text messages where we are not the intended recipient (such as messages that we host as a Controller but are not sent to us).
• inferences drawn from any of the above.

3. Processing your Personal Data. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on other legal bases to collect and process your Personal Data. We process your Personal Data for the following purposes:

• Providing our services, products, and website access: We process your Personal Data relating to your access of our services, products, website, and other Digital Properties (e.g., IP address, internet activity, account information, etc.) to ensure both you and we meet our obligations under the applicable contract, terms of use, or service agreement and to project future demand as well as improve our websites and services; absent a contractual relationship, we process your Personal Data to further our legitimate interest in operating and improving our websites and services.
• Internal business purposes: We process your Personal Data to operate, maintain, and improve our services, products, and website, including customizing the content; maintaining internal business records, such as accounting, managing user accounts, document management and similar activities; enforcing our policies and rules; monitoring service usage, management reporting; auditing; and IT security and administration to meet our obligations to you to perform our contract with you, or, if no contract applies, to the extent it is necessary for our legitimate interest in operating our business in a secure and efficient manner.
• Internal research and product improvement purposes: We process your Personal Data to verify and maintain the quality or safety of our products or services; improve our products or services; design new products and services; evaluate the effectiveness of our advertising or marketing efforts; and debug and repair errors with our systems, networks, and equipment to perform our contract with you, or, if no contract applies, to the extent it is necessary for our legitimate interest in improving our products and services.
• Securing our facilities, websites and services: We process your Personal Data (e.g., name, IP address, account information, internet activity) as part of our efforts to maintain, monitor and secure our facilities, websites, services, and products. This may include aggregating data, verifying accounts, investigating suspicious activity, and enforcing our terms and policies to the extent necessary to further our legitimate interest in maintaining a safe and secure website, products and services and in protecting our rights and the rights of others.
• Responding to contact requests: If you contact us electronically or by phone, we process your Personal Data (e.g., name, account information, government identifiers) to perform our contract with you, or, if no contract applies, to the extent it is necessary for our legitimate interest in responding to your inquiry and communicating with you. We may record and process communications for training, quality assurance, and administration purposes. If required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded.
• Managing payments: We may process your financial information and other Personal Data (e.g., name, account information, financial history) to verify financial information and to collect or make payments to the extent that doing so is required to fulfil our contract with you.
• Marketing and advertising: We may process your Personal Data (e.g., name, account information, purchase history, internet activity) to advertise to you, conduct market research, and to provide other personalized content based upon your Personal Data to the extent it is necessary for our legitimate interest in advertising our websites, services or products. Where legally required, we will obtain your consent before engaging in any marketing or advertising.
• Complying with legal and safety obligations: We process your Personal Data (e.g., name, account information, payment history, internet history) when cooperating with public and government authorities, protecting our legal rights, conducting audits, and protecting against abuse of our services and products. Any such processing is based on our legitimate interest in protecting our legal rights or, when applicable, complying with a legal obligation to which we are subject.
• In connection with a corporate transaction: We may process your information if we sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change in furtherance of our legitimate interest in operating and transacting the business of the company.

In some cases, we may provide specific services or offerings subject to separate or supplemental privacy policies. In those cases, we will prominently inform you of those policies and provide those policies in an easily accessible format.

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4. Exclusions. This Privacy Policy does not apply to Personal Data that:

• We process on behalf of our customers in the role of processor or other service provider, such as when we allow customers to create their own websites/applications to offer their own products and services, to send electronic communications to others; or otherwise use, collect, share or process Personal Data via our online products and services. Our customers’ privacy policies may be different from ours, and we are not responsible for those practices.
• We process about current or former employees, job applicants, and other individuals who interact with us for employment-related purposes.

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5. Cookies. Our Digital Properties and authorized third parties use Cookies to collect information about you, your device, and how you interact with our Digital Properties via Cookies. 

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6. How We Disclose Personal Data. We may disclose Personal Data to third parties, including the categories of recipients described below:

• Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, data and web hosting providers, software service providers, email marketing providers, payment processing companies, data analytics providers, and companies that provide business support services, financial administration, or event organization.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete transactions you request, such as shipping companies and logistics providers. 
• Law enforcement, government agencies, or other regulators to comply with law or legal requirements, to enforce our agreements, and to protect our rights and the property or safety of iTradeNetwork, our users, or third parties.
• Business partners that may use Personal Data for their own purposes such as:
  
  • Advertisers, ad platforms and networks, and social media platforms;
  • Third parties whose cookies and tracking tools we use as described in the Cookie and Tracking Technologies section.
  • Commercial data partners to whom we make information available for their own marketing purposes; and
  • 3rd party partners who work with us or provide distribution pathways, sales channels, and/or promotional opportunities including co-branded products and services.
• Transactional parties if we, or some or all of our assets, acquire or are acquired by another entity, including through a sale or in connection with a bankruptcy. 
• Your employer or coworkers if you receive our products or services in connection with your employment. 
• The public, or others with access to our Services and Services, such as when you have an opportunity to make comments, post information, or otherwise share your Personal Data in public areas of our products, services, or website.
• Entities to which you have consented to the disclosure.

Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where our business partners use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those business partners for details on their practices. We may also sell or share deidentified or aggregated data derived from your Personal Data to third parties for any purpose subject to reasonable protections to prevent reidentification. 

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7. Protecting Personal Data.

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information. Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us via email at privacy@itradenetwork.com.

8. Children.

Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. Generally, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us via email at privacy@itradenetwork.com, and we will take prompt steps to delete the information.

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9. Promotional and Marketing Policy.

‍We may ask you to consent to being contacted by us for promotional and marketing purposes. However, you may opt-out of receiving promotional or marketing emails at any time by notifying us as a reply to any unwanted e-mail, by using the unsubscribe function in our newsletter, contacting us at privacy@itradenetwork.com or by writing to us at PO Box 12409, Pleasanton, CA 94588. Requests to unsubscribe from iTradeNetwork e-mails may take 5 business days to process.

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10. External Links. Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

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‍11. Supplemental U.S. States Privacy Disclosures‍

1. Data Subject Rights. Depending on our relationship with you (i.e., whether you are an Individual or a Business Contact), and in which state you reside within the United States (such as California, Colorado, Oregon, or Delaware), you may have certain rights regarding Personal Data that you can exercise via our webform:  https://www.itradenetwork.com/legal/privacy-policy, or by emailing us at privacy@itradenetwork.com:privacy@itradenetwork.com:
   
   1. Right to Know. You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you. Oregon and Minnesota residents may also request a specific list of third parties to whom we disclose your Personal Data.Right to Delete. You may have the right to request that we delete Personal Data that we have collected about you.Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
   2. Right to Delete. You may have the right to request that we delete Personal Data that we have collected about you.
   3. Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
   4. Right to Opt Out of Sale, Sharing, and Targeted Advertising. You may have the right to opt out of selling, sharing, and targeted advertising (as such terms are defined under applicable laws). We do not knowingly sell data about minors under 18. In order to exercise the Right to Opt Out of Sale, Sharing, and Targeted Advertising, you must undertake both of the following steps:
      
      1. Request an Opt Out of Sale, Sharing, and Targeted by sending an email to privacy@itradenetwork.com.
      2. Disable the use of advertising Cookies in the preference center. You must complete this step on each of our websites from each browser and on each device that you use. These steps are necessary so that we can place a first-party Cookie signaling that you have opted out on each browser and each device you use.
         
         Please note: If you block Cookies, we will be unable to comply with your request to Opt Out of Sale, Sharing, and Targeted Advertising with respect to device data that we automatically collect and disclose to third parties online using Cookies. If you clear Cookies, you will need to disable the use of all advertising Cookies in the preference center again on each browser on each device where you have cleared Cookies.
         
         To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.
         
         We will not discriminate against you for exercising your privacy rights.
         
         To process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request.
         
         1. For Requests to Opt-Out of Sale, Sharing, and Targeted Advertising: We collect your name and email to locate you in our records.
         2. For Requests to Know, Delete, and Correct: We collect information necessary to verify your identity and that you are a resident of a state that provides for these rights, including name, mailing address, email address, phone number, relationship to iTradeNetwork.
2. Authorized Agents. Authorized agents may exercise rights on your behalf by submitting a request via email to privacy@itradenetwork.com or by using our webform at https://www.itradenetwork.com/legal/privacy-policy.
   
   1. If you designate an authorized agent to submit a Request to Know, Delete, or Correct, we may reach out to you directly to verify your own identity or to confirm that you provided the authorized agent with permission to submit the request.
   2. If you designate an authorized agent to submit a Request to Opt Out of Sale, Sharing, and Targeted Advertising, we may seek additional information directly from the authorized agent to process the request.
3. Appeal. If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us at privacy@itradenetwork.com We will inform you in writing our response to your appeal.
4. Nevada residents: Individuals may contact us at privacy@itradenetwork.com to inquire about your right to opt out of the sale of your Personal Data.

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12. Additional Data Processing Disclosures for California Residents

In addition to the disclosures above, this section provides supplemental information about how we process Personal Data. These additional disclosures apply only to individuals who reside in California as required by the California Consumer Privacy Act (“CCPA”).

a. Disclosure of Personal Data

Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business purpose in the past 12 months.

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b. California Shine the Light:

If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by opting out and following all of the instructions for opting out of disclosures that may be a “sale” or “sharing” for targeted advertising.  

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13. Canadian Residents

Canadian residents may contact our Lead Privacy Advocate at privacy@itradenetwork.com. Canadian individuals have the right to complain to the Office of the Privacy Commissioner of Canada (OPC), or in Quebec to the Commission d'accès à l'information (CAI) 

a. Legal Bases for Processing

We process the following categories of personal data for the following processing purposes based on the following legal bases:

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b. Your Data Protection Rights

Under the conditions set by applicable data protection laws, you may exercise certain rights regarding your Personal Data.

• Right to Access.  You have the right to obtain confirmation from us whether we are processing your Personal Data and related information, as well as the right to obtain a copy of your Personal Data undergoing processing.
• Right to Data Portability.  You may receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format.
• Right to Rectification.  You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.
• Right to Objection.  You have the right to object to the processing of your Personal Data in certain cases.
• Right to Restrict Processing.  You may request that we restrict the processing of your Personal Data in certain cases.
• Right to Erasure.  You may request that we erase your Personal Data in certain cases.
• Right to Lodge a Complaint.  You have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.
• Right to Refuse or Withdraw Consent.  In case we ask for your consent to process your Personal Data, you are free to refuse to give it.  If you have given your consent, you may withdraw it at any time without any adverse consequences.  The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.‍
• Right to Not Be Subject to Automated Decision-making. You have the right not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.

You may exercise these rights by contacting us at privacy@itradenetwork.com or by submitting the webform located at https://www.itradenetwork.com/legal/privacy-policy 

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COOKIE POLICY

This Cookie Policy describes how iTradeNetwork Inc.  (“COMPANY,” “we,” “us,” or “our”) uses cookies, pixels, and similar technologies (collectively referred to as “Cookies”) on our websites, mobile applications, online advertisements, digital platforms, online communications (e.g., email), and other digital products and services (collectively, our “Digital Properties”). In this Cookie Policy, we explain:

• The types of Cookies we use
• What information we collect using these Cookies
• The purposes for which we use these Cookies
• How we disclose or make information collected through these Cookies available to others
• Choices you may have regarding these Cookies
• A general list of the individual Cookies we currently use or recently have used

The information in this Cookie Policy supplements our Privacy Notice, which describes our general privacy practices. 

1. Types of Cookies We Use

Our Digital Properties and the third parties that we authorize may use:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit our Digital Properties. 
• Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier.  In addition to the uses described below, these technologies provide information about interactions with our Digital Properties, (including communications such as email we may send to you) and help us customize our marketing activities. In contrast to cookies, which are stored on a user's device hard drive, pixels, web beacons, and tags are embedded invisibly on our Digital Properties. 
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms.  In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom experiences on our Digital Properties.  Embedded scripts are temporarily downloaded onto your device from our web server, or from a third party with which we work, and are active only while you are connected to our Digital Properties and are deleted or deactivated thereafter.

We may use both first-party Cookies, which are set by us, and third-party Cookies, which are set by other parties. Some of the Cookies we use may last solely for your browsing session and are deleted when you close your browser, while others are persistent and stored after you close your browser.

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2. Types of Data Collected

We may collect the following types of data about you or your device through Cookies:

• IP address
• Location (both approximate and precise)
• Cookie ID
• Device ID
• Ad ID
• Operating system
• Device type
• Device settings and other device information
• Browser type
• Browser history
• Search history
• Search queries
• Login information
• Shopping cart information
• Information entered into webforms
• Pages viewed
• Other data about your interactions with our Digital Properties

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3. Uses of Data

We and authorized third parties use Cookies for purposes including:

• Strictly Necessary: These are technologies that our Digital Properties need to function, and that enable you to move around and use the Digital Properties.  Without these Cookies, the Digital Properties will not perform as smoothly for you as we would like them to, and we may not be able to provide the Digital Properties or certain features you request.  For example, we use these Cookies to determine when you are signed in, to determine when your account has been inactive, to provide you with privacy disclosures and choices, and for troubleshooting and security purposes.  We refer to Cookies used for this purpose as “Strictly Necessary” Cookies in this Cookie Policy;
• Functionality/Personalization: These are technologies that help enhance functionality, improve your user experience, and tailor your use of our Digital Properties.  For example, Functionality Cookies can be used to remember pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties.  We refer to Cookies used for this purpose as “Functional” Cookies in this Cookie Policy; 
• Performance/Analytics: These technologies allow us to understand more about how visitors use our Digital Properties so we can understand and improve performance.  For example, we gather analytics to help us understand which pages within our Digital Properties are most popular and how users move around them. For example, we use Google Analytics to help us improve our Digital Properties’ functionality.  Google may use cookies to provide Google Analytics. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/technologies/partner-sites. We refer to Cookies used for this purpose as “Performance” Cookies in this Cookie Policy; and

Targeting: These are technologies used for targeted advertising and marketing. For example, we use Cookies and conversion tracking tools to improve the effectiveness of our online marketing efforts (such as personalized advertisements placed on other Digital Properties you may visit). We refer to Cookies used for this purpose as “Targeting” Cookies in this Cookie Policy.

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4. Disclosures of Data

We may disclose data collected through Cookies to the following types of recipients or allow the following recipients to directly collect data using Cookies:

• Social media companies;
• Advertising networks;
• Analytics providers (including providers of ad tracking and reporting services);
• Security providers; and
• Other technology providers and business partners.

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5. Your Choices

You can control how we use Cookies.  Please be aware that if you disable the use of Cookies, the functionality of our Digital Properties may be negatively impacted, and certain areas or features may not display or work correctly.

a. Preference Center

You can modify your Cookie consent preferences at any time by clicking "Privacy Settings" in the footer.

b. Browser Settings

If you want to disable the use of certain specific Cookies or remove them from your device, you can disable or delete them using your browser settings.  Please be aware that not all Cookies can be deleted through browser settings. The following links contain instructions for commonly used browsers: Apple Safari; Google Chrome; Microsoft Edge; and Mozilla Firefox.  

c. Interest-Based Advertising 

In addition to any other rights you have as described in our Privacy Notice, some of the third parties we work with participate in industry groups offer mechanisms to opt out of interest-based advertising. Residents of Europe can use the European Interactive Digital Advertising Alliance’s opt-out tool at https://www.youronlinechoices.eu/, and residents of the United States can use the Digital Advertising Alliance’s mechanism at https://youradchoices.com/. Opting out of interest-based advertising using these tools will not opt you out of all advertising, but rather only interest-based advertising from us or our partners or representatives. 

If you are using a mobile device, you can manage interest-based ads on your device by adjusting the settings provided by your device manufacturer or the operating system provider: Manage settings on iOS devices; and Manage settings on Android devices.

d. Do Not Track

Web browsers and other technologies you may use to access the Digital Properties may include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your preference to not have data about your online browsing activities monitored and collected over time and across websites.  At this stage, we do not currently respond to DNT browser signals or similar mechanisms.

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6. Contact Us

If you have any questions regarding our Cookie Policy, please contact us at:

privacy@itradenetwork.com