PRIVACY POLICY

Last Updated: June 8, 2025

1. INTRODUCTION

Two Bit da Vinci, Inc. (“we,” “our,” or “us”) operates twobitdavinci.com (the “Service”). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. INFORMATION WE COLLECT

2.1 Personal Information

We may collect personally identifiable information that you voluntarily provide to us when you:

• Register for an account
• Subscribe to our newsletter
• Contact us through our website
• Use our services
• Participate in surveys or promotions

This information may include:

• Name
• Email address
• Phone number
• Mailing address
• Payment information
• Username and password
• Profile information

2.2 Usage Data

We automatically collect certain information when you visit, use, or navigate our Service. This information may include:

• IP address
• Browser type and version
• Operating system
• Referring website
• Pages visited and time spent on pages
• Device information
• Location data (with your permission)

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Service and store certain information. Types of cookies we use:

• Essential Cookies: Necessary for the website to function properly
• Analytics Cookies: Help us understand how visitors interact with our website
• Marketing Cookies: Used to track visitors across websites for advertising purposes
• Preference Cookies: Remember your preferences and settings

3. HOW WE USE YOUR INFORMATION

We use the collected data for various purposes:

• To provide and maintain our Service
• To process transactions and send transaction confirmations
• To communicate with you, including customer service and support
• To send you marketing communications (with your consent)
• To improve our Service and develop new features
• To monitor usage and analyze trends
• To detect, prevent, and address technical issues and fraud
• To comply with legal obligations
• To protect our rights and interests

4. LEGAL BASIS FOR PROCESSING (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using personal information depends on the information and the context:

• Consent: You have given clear consent for processing
• Contract: Processing is necessary for a contract with you
• Legal Obligation: Processing is necessary to comply with the law
• Legitimate Interest: Processing is necessary for our legitimate interests

5. INFORMATION SHARING AND DISCLOSURE

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers

We may employ third-party companies and individuals to:

• Facilitate our Service
• Provide the Service on our behalf
• Perform Service-related services
• Assist us in analyzing how our Service is used

These third parties have access to your personal data only to perform these tasks and are obligated not to disclose or use it for any other purpose.

5.2 Business Transfers

If Two Bit da Vinci, Inc. is involved in a merger, acquisition, or asset sale, your personal information may be transferred as part of that transaction.

5.3 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.4 Protection of Rights

We may disclose your information when we believe in good faith that disclosure is necessary to:

• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Investigate fraud or respond to a government request

6. DATA RETENTION

We will retain your personal information only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your information to:

• Comply with our legal obligations
• Resolve disputes
• Enforce our agreements

When your personal information is no longer required, we will securely delete or anonymize it.

7. DATA SECURITY

The security of your data is important to us. We implement appropriate technical and organizational security measures to protect your personal information against:

• Unauthorized access
• Alteration
• Disclosure
• Destruction

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. YOUR DATA PROTECTION RIGHTS

Depending on your location, you may have the following rights regarding your personal data:

8.1 General Rights

• Access: Request copies of your personal data
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Restrict Processing: Request that we limit the processing of your personal data
• Data Portability: Request transfer of your data to another organization
• Object: Object to our processing of your personal data

8.2 California Privacy Rights (CCPA)

If you are a California resident, you have additional rights:

• Right to know what personal information is collected
• Right to know whether personal information is sold or disclosed
• Right to say no to the sale of personal information
• Right to access personal information
• Right to equal service and price

8.3 European Privacy Rights (GDPR)

If you are in the EEA, you have additional rights under GDPR:

• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority

9. EXERCISING YOUR RIGHTS

To exercise any of your rights, please contact us using the information provided in the “Contact Us” section. We will respond to your request within 30 days (or as required by applicable law).

10. CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

11. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ. If you are located outside the United States and choose to provide information to us, we transfer the data, including personal data, to the United States and process it there.

12. THIRD-PARTY LINKS

Our Service 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, as we have no control over and assume no responsibility for third-party content, privacy policies, or practices.

13. DO NOT TRACK SIGNALS

We do not currently respond to “Do Not Track” signals from browsers. However, you can disable cookies through your browser settings.

14. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy on this page
• Updating the “Last Updated” date
• Sending you an email notification (for significant changes)

You are advised to review this Privacy Policy periodically for any changes.

15. CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us:

Two Bit da Vinci, Inc.
Website: twobitdavinci.com

For privacy-related inquiries, you may also contact our Data Protection Officer at: [email protected]

This Privacy Policy is effective as of June 8, 2025.