PRIVACY POLICY

Last Updated: August 16, 2025

1. Introduction

This Privacy Policy explains how DoublePenniesOnline LLC (“Company,” “we,” “our,” or “us”) collects, uses, shares, and protects personal information when you use our website and related services (“Services”). By using the Services, you agree to the practices described in this Privacy Policy.

2. Information We Collect

a. Information You Provide: account registration details (name, email, etc.), content you submit, and payment information (processed securely by third parties).

b. Automatically Collected Information: device type, browser, IP address, cookies, usage data.

c. Sensitive Data: The Company does not intentionally collect sensitive categories of personal data (e.g., biometric, precise geolocation, health) unless necessary for program participation and only with explicit consent.

3. Legal Basis for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) applies, we process personal data based on one or more lawful bases: (i) consent; (ii) contract necessity; (iii) legal obligations; (iv) legitimate interests (research and program improvement).

4. How We Use Information

We use collected information for: program operations and research (aligned with NAICS Code 541720), communication with users, compliance with laws, fraud prevention, analytics, and service improvement.

5. How We Share Information

We do not sell personal data. We may share information with:

- Service providers (e.g., payment processors, hosting, IT support, analytics).

- Legal/regulatory authorities when required by law.

- Research partners, but only in anonymized/aggregated form.

All third-party processors are contractually required to safeguard personal data and use it only for authorized purposes.

6. International Data Transfers

If you access the Services outside the U.S., your information may be transferred to and processed in the U.S. We rely on recognized safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms for international transfers.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to improve functionality, analyze usage, and support research. You can disable cookies through browser settings, but certain features may not function properly.

8. Data Security

We implement reasonable physical, administrative, and technical safeguards to protect information. However, no system is 100% secure. In the event of a data breach, we will notify affected users and regulators as required by applicable law.

9. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, unless longer retention is required by law. For example:

- Account information: retained for up to 3 years after closure.

- Transaction data: retained for 7 years for compliance purposes.

- Research data: may be retained in anonymized form indefinitely.

10. Children’s Data

We do not knowingly collect personal data from children under 13. Users under 18 may participate only with verified parental/guardian consent. If we collect data with parental consent, verification will be conducted through acceptable methods such as government ID, signed forms, or other legally recognized verification processes.

11. Your Privacy Rights

Depending on your location, you may have rights including:

- Accessing, correcting, or deleting your personal data.

- Requesting data portability.

- Opting out of targeted advertising or data sharing (as required by CCPA/CPRA).

- Withdrawing consent (where processing is based on consent).

- Appealing denied requests (as required by certain U.S. state privacy laws).

You may exercise these rights by contacting us support@doublepennies.online.

12. Dispute Resolution & Class Action Waiver

Any disputes relating to this Privacy Policy shall be resolved under the Dispute Resolution provisions in the Company’s Terms & Conditions, including binding arbitration and a waiver of class actions.

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be posted on the Website. Continued use of the Services after changes constitutes acceptance.

14. Contact Us

DoublePenniesOnline LLC

Email: support@doublepennies.online