Definitions and legal references

This website (or this Application)

The property that enables the provision of the Service.

Owner (or We)

DIE’s Portfolio, LLC – The natural person(s) or legal entity that provides this website and/or the service to users.

User (or You)

The natural person or legal entity that uses this website.

Service

The service provided by this website as described in these Terms and on this website.

Personally Identifiable Information

Refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.

This document contains a section dedicated to Brazilian users and their privacy rights.

What Personally Identifiable Information is collected?

We may collect basic user profile information from all of our users. We collect the following additional information from our users: the name, email address, phone number, that the user intends to purchase or sell.

What organizations are collecting the information?

In addition to our direct collection of information, our third party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect this information from our users. We do not control how these third parties use such information, but we do ask them to disclose how they use personal information provided to them from users. Some of these third parties may be intermediaries that act solely as links in the distribution chain, and do not store, retain, or use the information given to them.

How does DIE’s Portfolio, LLC use Personally Identifiable Information?

We use Personally Identifiable Information to customize the website, to make appropriate service offerings, and to fulfill buying and selling requests on the website. We may email users about research or purchase and selling opportunities on the website or information related to the subject matter of the Website. We may also use Personally Identifiable Information to contact users in response to specific inquiries, or to provide requested information.

How is Personally Identifiable Information stored?

Personally Identifiable Information collected by DIE’s Portfolio, LLC is securely stored and is not accessible to third parties or employees of DIE’s Portfolio, LLC except for use as indicated above.

What options are available to users regarding collection, use and distribution of the information?

Users may opt out of receiving unsolicited information from or being contacted by us and/or our vendors and affiliated agencies by responding to emails as instructed, or by either :

• Emailing us at contactde@diesportfolio.com

Are cookies used on the Website?

Cookies are used for a variety of reasons. We use cookies to obtain information about the preferences of our users and the services they select. We also use cookies for security purposes to protect our users. For example, if a user is logged on and the website is unused for more than 10 minutes, we will automatically log the user off. Users who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using
https://diesportfolio.com ,
with the drawback that certain features of the website may not function properly without the aid of cookies.

How does DIE’s Portfolio, LLC use login information?

DIE’s Portfolio, LLC uses login information, including, but not limited to, IP addresses, ISPs, and browser types, to analyze trends, administer the website, track a users movement and use, and gather broad demographic information.

What partners or service providers have access to Personally Identifiable Information from users on the website?

DIE’s Portfolio, LLC has entered into and will continue to enter into partnerships and other affiliations with a number of vendors. Such vendors may have access to certain Personally Identifiable Information on a need to know the basis for evaluating users for service eligibility. Our privacy policy does not cover their collection or use of this information. Disclosure of Personally Identifiable Information to comply with the law. We will disclose Personally Identifiable Information in order to comply with a court order or subpoena or a request from a law enforcement agency to release information. We will also disclose Personally Identifiable Information when reasonably necessary to protect the safety of our users.

How does the Website keep Personally Identifiable Information secure?

All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our users is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols, in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering, and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to users for any such occurrences.

How can users correct any inaccuracies in Personally Identifiable Information?

Users may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by either:

• Emailing us at contactde@diesportfolio.com

Can a user delete or deactivate Personally Identifiable Information collected by the website?

We provide users with a mechanism to delete/deactivate Personally Identifiable Information from the website’s database by contacting. However, because of backups and records of deletions, it may be impossible to delete a users entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

User rights

These are summarized rights that you have under data protection law:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to complain to a supervisory authority
• The right to withdraw consent

What happens if the Privacy Policy changes?

We will let our users know about changes to our privacy policy by posting such changes on the website. However, if we are changing our privacy policy in a manner that might cause disclosure of Personally Identifiable Information that a user has previously requested not be disclosed, we will contact such user to allow such user to prevent such disclosure.

Links to other websites

DIE’s Portfolio, LLC contains links to other websites. Please note that when you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.

GDPR Privacy Policy

DIE’s Portfolio, LLC (“us”, “we”, or “our”) is committed to respecting your privacy. This privacy policy informs you about how our organization collects, stores and uses your personal data that you provide when you use our website.

Topics included:

• What data do we collect?
• How do we collect and use your data?
• Data used for marketing or shared with third parties
• What are your data protection rights?
• Privacy policies for other websites
• Changes to our privacy policy
• How to contact us?

What data do we collect?

We collect your personal information. Personal information is any data that relates to an individual to use as identification like:

• Personal identification information – This data is provided by you for registration and for using other services – name, email address, phone number, country, state, etc.
• Browser and visit information – This data is provided by your browser and visits you made on our website – browser type, operating system, IP address, demographics, etc.
• Cookie-related information – See cookie policy for cookie-related details.

However, you can browse our website without providing your personal information.

How do we collect and use your personal information?

Collection of personal information

We collect your data in the following forms:

• Register online or place an order for any products or services
• Complete a survey or provide feedback on our products or services or via emails
• Visit our website using your browser’s cookies

Use of personal information

We use your personal information for the following purposes:

• To create and manage your account on our website
• To process details related to your orders and refunds
• To identify you once you register on our website
• To provide you better usability and service
• To contact you and respond to your queries and feedbacks
• To understand which sections of the website are visited and how frequently

Data used for marketing or shared with third parties

Data used for marketing

Based on your preference, our organization would like to send you marketing emails for products, services, and offers that you might like. You have the right at any time to stop our organization from contacting you. You can anytime opt-out of our marketing-related emails at a later date.

Data sharing with third-party sites

Our organization will never share your personal information with third-party sites without taking prior permission from you. Though, we share your personal information within the organization, business partners, authorized third-party services.

What are your data protection rights?

We would like to make sure that you are fully aware of your data protection rights. Every user is entitled to the following rights:

• The right to access – You have the right to ask for copies of your personal information provided to us.
• The right to rectification – You have the right to tell us to correct the personal information that you believe needs correction. You also have the right to complete the information you believe is incomplete.
• The right to erase – You have the right to ask us to erase all your personal data at any time.
• The right to object – You have the right to object to our organization’s processing of your personal data, under certain conditions.
• The right to data portability – You can anytime ask us to transfer your personal information to any other organization or directly to you, under certain conditions.

Privacy policies for other linked websites

Our website contains links from and to other websites. However, our privacy policy applies to only our website and not other linked websites. So, if you click on a link to other websites, you can read their privacy policy.

Changes to our privacy policy

Our organization reviews and updates its privacy policy on a regular basis. We may change our data privacy practices and place any updates on this privacy policy page.

How to contact us?

If you have any queries related to our data privacy practices or this privacy policy, feel free to contact us at contactde@diesportfolio.com

California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by DIE’s Portfolio, LLC to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to contactde@diesportfolio.com

We take great pride in the relationship of trust and we are dedicated to treating your personal information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), DIE’s Portfolio, LLC does not share guests’ personal information with other companies or others outside for those parties’ direct marketing use unless a guest elects that we do so.  For more information about our privacy and data collection policies, you may wish to review our Privacy Policy.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to contactde@diesportfolio.com . Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Privacy Notice For California Residents

This Privacy Notice for California Residents supplements the information contained in the Website’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

The Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, Website has collected the following categories of personal information from its consumers within the last 12 months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like certain health or medical information and other categories of information protected by different laws.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates’ assets in which personal information held by us or our affiliates about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Data Aggregators.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we’ve collected about you.
• The categories of sources for the personal information we’ve collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we’ve collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at contactde@diesportfolio.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we’ve collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contactde@diesportfolio.com.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Email: contactde@diesportfolio.com

Information for Users residing in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This section of the document uses the term “personal information” as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows :

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section “Detailed information on processing of Personally Identifiable Information” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the section “Detailed information on processing of Personally Identifiable Information” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to :

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases :

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Last Updated: March 2, 2022