Privacy Policy

1. Definitions

In this Policy, the following terms have the meanings indicated below:

• Personal Data : any information relating to an identified or identifiable natural person.
• Processing : any operation performed on personal data.
• Data Controller : LevelARA Group, which determines the purposes and means of processing.
• Processor : any entity processing data on behalf of LevelARA Group.
• Platform : the LevelARA Invest-Market website and all its services.
• User : any person registered on the Platform.
• Visitor : any person browsing the Platform without being registered.

2. Data Controller Identity

Company name: LevelARA Group

Legal form: Limited Liability Company (LLC)

Headquarters: 150 Grossman Drive, Suite 205, Braintree, MA 02184, United States

Trade register: State of Massachusetts

Data Protection Officer email: privacy@levelaragroup.com

3. Categories of Data Collected

We collect only data strictly necessary for the provision of our services.

3.1 Identification data

• Username, email address, password (stored securely)
• First and last name (optional depending on the service)
• Phone number and postal address (only if necessary)

3.2 Transaction data

• Purchase history, amounts, invoicing
• Wallet or seller revenue information

3.3 Browsing data

• IP address (temporary retention for security)
• Pages visited, browser type

4. Legal Basis for Each Processing

In accordance with the GDPR, each processing is based on:

• Contract performance (account creation, orders, payments)
• Explicit consent (contact messages, applications, non-essential cookies)
• Legitimate interest (security, audience analysis)
• Legal obligation (accounting retention)

5. Data Recipients

We do not sell, rent, or transfer your personal data to third parties for commercial purposes.

Your data is accessible to:

• Authorized LevelARA Group personnel
• Technical processors (payment, hosting, email delivery)
• Competent authorities upon legal request

6. International Data Transfers

Your data may be hosted or processed outside the European Union. These transfers are governed by:

• The Data Privacy Framework (for certified processors)
• Standard contractual clauses of the European Union

7. Retention Periods

• User account: 30 days after deletion request
• Orders / transactions: 10 years (accounting obligation)
• Contact messages: 3 years after the last exchange
• Technical logs (IP): 30 days maximum
• Session cookies: session duration
• Audience cookies: 13 months maximum

Beyond this, data is deleted or anonymized.

8. Your Rights

You have the following rights (Articles 15 to 22 of the GDPR):

• Right of access, rectification, erasure
• Right to restriction, portability, objection
• Right to withdraw your consent at any time

To exercise your rights: privacy@levelaragroup.com
Response time: 30 days maximum.

In case of dispute, you may contact the CNIL or the competent supervisory authority.

9. Cookie Policy

We use:

• Essential cookies (authentication, cart, session) — no consent required
• Audience measurement cookies (anonymous statistics) — with explicit consent

You can manage cookies through your browser settings.

10. Security Measures

We implement technical and organizational measures in line with industry standards:

• Encryption of communications (HTTPS)
• Secure storage of passwords and sensitive data
• Enhanced authentication and strict access management
• Regular encrypted backups
• Appropriate network monitoring and protection

11. Protection of Minors

The Platform is prohibited to persons under 18 years of age. If we discover an account belonging to a minor, we will delete it as soon as possible.

12. Data Breach Notification

In the event of a data breach likely to result in a high risk to your rights:

• Notification to the supervisory authority within 72 hours
• Information to affected users if required by law

13. Policy Changes

Any substantial change will be notified to you by email at least 8 days before it takes effect.

14. Contact and Complaints

Data Protection Officer:

LevelARA Group

150 Grossman Drive, Suite 205, Braintree, MA 02184, United States

Email: privacy@levelaragroup.com

Supervisory authority:
CNIL — 3 Place de Fontenoy, 75334 Paris Cedex 07, France
https://www.cnil.fr
Find a copy of the GDPR here