I. Introduction and Policy Scope

The purpose of this Privacy Policy is to inform you about the types of information you may provide to us or that we may collect from you and our practices for collecting, using, protecting, and disclosing that information. This Privacy Policy applies to all information we collect or which is provided through our website (microcaps.com) and any websites or mobile applications that are owned and operated by SRAX, Inc. and/or our affiliates (“Company”, “we,” “our,” or “us”), other than those websites or mobile applications which have their own privacy policies (collectively, “Our Sites”).

This Privacy Policy also applies to (a) all email and other electronic messages between you and the Company or through Our Sites, and (b) the information provided or collected when you interact with our advertising and our application(s) even if provided through third-party websites and services.

This Privacy Policy does NOT apply to information collected by third parties, including any third-party application(s) or content that may link to or be accessible from Our Sites. Your use of such third-party application(s) and/or content may be subject to such third-party’s privacy policy and we encourage you to read such third-party’s privacy policy.

Also, to clarify, some websites and/or applications owned by us and/or our affiliates may have separate privacy policies that are applicable to such websites/applications and which differ from the terms of this Privacy Policy, including certain websites or applications to which Our Sites provide a link. We encourage you to read such separate privacy policies.

II. What Information We Collect and Process

The Information you provide to us or we may collect from you is described in the sections below.

Please be aware that such information may include information or data that you consider sensitive or by which you may be personally identified (“personal information”). Depending on the law applicable to you, the information that you provide or we collect and which may be deemed personal information may include: your name, physical address, email address, online identifier, profile information, information regarding your interaction with Our Sites, or telephone number.


Information you provide to us may include:

● Information that you choose to upload, link, or otherwise make available to Our Sites.
● Information that you provide by filling in forms on Our Sites, including information provided at the time of registering or updating your account on Our Sites.
● Records and copies of your correspondence or communication with us or on Our Sites, including email addresses.


In addition to the information described under “Online Tracking” below, the information we collect about you includes the following:

● Information from third parties, for example, our business partners, including information from advertising partners regarding your activities outside Our Sites (e.g., information about your device, demographics and behaviors).
● Details of transactions you authorize through Our Sites, including transaction information provided to us by third parties or categories of third parties to whom you have chosen to make your information available through Our Sites (“Transaction Information”).



We may collect and use your phone number for the purpose of providing you with important updates, notifications, information related to our products, services, transactions, and account activities, as well as occasional marketing messages. By providing your phone number, you consent to receive SMS messages from us for these purposes. These messages may include but are not limited to transactional notifications, account-related alerts, security verification codes, marketing promotions, and updates about your interactions with us.

Please note that standard messaging and data rates may apply depending on your mobile carrier and plan. You can opt-out of receiving SMS messages for marketing purposes at any time by following the instructions provided in the SMS messages or by contacting our customer support. Opting out of marketing SMS messages will not affect your ability to receive important updates and notifications.

We want to assure you that we do not sell your phone number or any of your personal data to third parties for marketing purposes. Your privacy and data security are of utmost importance to us.

By providing your phone number and consenting to receive SMS messages, you acknowledge that you have read and understood this use of phone numbers and SMS clause in our privacy statement.


Data Collection Technologies

As you navigate through and interact with Our Sites, we may use automatic data collection technologies (such as cookies, web beacons, and pixel tags) to collect certain “usage information” about how you use Our Sites and about your equipment, browsing actions, and patterns, including:

● Details of your visits to Our Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on Our Sites.
● Information about your device and internet connection, including your device’s unique identifier, network information, IP address, operating system, platform, pages viewed, user agent strings, mobile ad identifiers (e.g., IDFA, Google AdID), geolocation data, browser type, linking information, click stream data, and/or website log files and browser and browser plug-in types. If we identify that you are accessing Our Sites through multiple devices, we may associate each such device with your profile.
● Our Sites may collect location information of your device using GPS or other location technologies.
● Information about your online activities over time and across third-party websites or other online services (behavioral tracking).

For more information about cookies and some of the other available tracking technologies see: https://www.allaboutcookies.org/. You can usually modify your web browser setting to decline cookies. Most web browsers automatically accept cookies as a default setting. If you choose to decline cookies, your ability to use Our Sites may be impaired and/or you may not be able to fully use all the features of Our Sites. You also have the ability to delete cookies files from your hard drive at any time.

Please note that use of Our Sites requires your consent to cookies as specified in our cookie policy.

We require this usage information to provide you with certain functionality of Our Sites as well as to assess and improve Our Sites. The information we collect automatically is generally statistical data but in some jurisdictions may include information included in a broad definition of personal information or data (e.g., IP address and certain location information or online identifiers), or we may maintain it or associate it with personal information we obtain in other ways.

Our Sites Service Partners and Data Collected

We currently use the services identified in the chart below to help us provide services on Our Sites and which collect information automatically. The service providers indicated in the chart, and the tracking technologies they use may change from time to time and we may engage new or different service providers from time to time. We intend to update this Privacy Policy periodically, but the chart below may be out of date. To confirm or receive a current list of service providers and tracking technology utilized in connection with Our Sites, please contact us as provided at the bottom of this Privacy Policy.

Partnering Technologies: Google Analytics
Function: Tracking and Analytics Our Sites
Information Collected: Detailed at: https://support.google.com/analytics/answer/7108387

III. How We Use Your Information

We use information that you provide or we collect, including any personal information, and including as combined with information already in our possession or made available to us, and/or information we obtain from other sources:

● To fulfill any purpose for which you provide it.
● To personalize and enhance your experience while interacting with Our Sites, partner sites, or partner mobile applications and applications.
● To operate and present Our Sites and their contents to you.
● To establish your online account and authenticate you during a registration or login to any of Our Sites or our other communications.
● In aggregate with other people’s data, to train machine-learning algorithms that help us better understand Our Sites’ users.
● To provide you with information, products, or services that you request from us.
● To deliver the type of content and services that we believe may be of interest to you, including emails, newsletters, alerts, and advertising targeted to your experience and/or interests, based on your professional or personal activities and/or other information we possess.
● To share your response information to our communications with the sponsor(s) of the relevant program with which you interact.
● To conduct audience-matched advertising to associate offline data with online data
● To provide you with notices about your account.
● To administer a contest, promotion, survey, or other feature.
● To carry out our obligations and enforce our rights under contract or law.
● To notify you about changes to Our Sites or services we offer or provide though it.
● In any other way we may describe when you provide the information.
● For any other purpose with your consent.
● To contact you about our own services that may be of interest to you.

IV. Reasons We May Share Your Information

We may disclose and use aggregated information about our users, and other information by which you cannot be identified (including information that has been de-identified), without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

● To third parties or categories of third parties to market their products or services to you, unless you have contacted us to make an election stating you don’t want certain third parties or categories of third-parties to have access to your data.
● To our affiliates.
● To contractors, service providers, and other third parties we use to support our business.
● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s or its corporate parent’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about Our Sites users is among the assets transferred.
● To fulfill the purpose for which you provide it.
● To the sponsor(s) of the relevant program with which you interact
● For any other purpose explicitly disclosed prior to you providing the information.
● With your consent.
● When we are under legal compulsion to do so (e.g., we have received a subpoena) or we otherwise believe that the law requires us to do so.
● When we believe it is necessary to protect and/or enforce the rights, property interests, or safety of the Company, Our Sites, our users, clients, or others.
● As we deem necessary to resolve disputes, troubleshoot problems, prevent fraud, and otherwise enforce the Privacy Policy and other Terms of Use.
● For such other purposes as we are permitted or required by applicable law to do so.

V. Your Rights Regarding Your Information

You may have certain rights under federal or state laws and regulations in the event that we have any personally information about you. You may contact us at any time with regards to your rights. Under applicable law, you may have the right to request that we:
• Provide a detailed explanation regarding the personal information we have collected about you and how we use that information.
• Receive a copy of the personal information we have collected about you.
• Request correction of any inaccurate personal information that we have about you.
• Erase or delete any of your personal information.
• Request to opt-out of certain marketing communication from us.
• You can make these requests by contacting us as specified in Section XII below.

You may also manage your marketing preferences by not providing information to us. However, to the extent that you choose to provide your personal information to us or to a Company client, you may be able to opt out of having your personal information used for certain purposes.

When conducting browser based opt out, it is necessary to perform the opt out activity on each browser or device you which to opt out from Microcaps advertising.
• You may opt out of receiving email communications by utilizing the opt-out mechanism found in each email sent by us or a verified third-party sending emails on our behalf to you. This will remove you from the email list or the website registration list and/or the sponsor of the communication.
• You may reset your advertising ID, see your device settings for how to reset this Ad ID.
• In addition, you may remove the email pixels that may track you and communicate information to us so long as they appear in the image cache of your Internet browser. You may remove the pixels simply by deleting the cache in which the pixel is stored.
• You may delete cookies by opening your browser’s “Internet Options” folder and making the appropriate selections.
• If you are unsure of how to clean your cache or delete cookies, locate the “Help” function in the browser menu. Entering in the search bar “clean cache” and “delete browser cookies” will return instructions specific to your browser.

VI. Security

We have implemented appropriate administrative, physical, and technical measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) access credentials for access to certain parts of Our Sites, you are responsible for keeping such credentials confidential. We ask you not to share your access credentials with anyone. You are liable for all use of Our Sites through your access credentials.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to, on, or through Our Sites via the internet.


VII. Children’s Policy

Our Sites are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you think that we have collected personal information from a visitor or user under the age of 13, please contact us as specified in Section XII below.

VII. U.S. Based Company

We are a U.S. based company. If you are located outside the U.S., any personal information you provide or we collect will be transferred to, stored and otherwise processed in the U.S.

We may transfer your personal information across national borders to other countries in compliance with applicable laws.

When we transfer your personal information from the European Economic Area (EEA) or Switzerland to a non-EEA country, we rely on one or more of the following legal mechanisms: our self-certification under the EU-U.S. Privacy Shield, Swiss-U.S. Privacy Shield, Standard Contractual Clauses, or your consent. For more information about our self-certification to the EU-U.S. Privacy Shield, including the scope of our certification, please see Privacy Shield/European data transfers.

If the content or data that you store on or through Our Sites contains the personal information of individuals from the EEA, you agree that you have the legal authority to transfer the personal information to us, including the transfer to countries such as the United States where the privacy protections and rights of authorities to access personal data may not be equivalent to those in the EEA.

We are committed to and comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We have self-certified to the Department of Commerce that we adhere to the Privacy Shield Principles on behalf of itself and its affiliates. If third-party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield framework, we remain liable unless we prove we are not responsible for the event giving rise to the damage. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

IX. Updates

We may update and/or change this Privacy Policy from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will also notify you by email to the email address specified in your account and/or through a notice on Our Sites. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting Our Sites and this Privacy Policy to check for any changes.

X. Supervisory Authority

If you are located within the European Union and European Economic Area and you believe that any processing of your personal information infringes the General Data Protection Regulation, you have the right to lodge complaints with a supervisory authority in the country of your habitual residence, place of work or place of the alleged infringement.

XI. California Residents

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes as permitted by this Privacy Policy. To make such a request, please contact us using the information in Section XII below. This request may be made no more than once per calendar year, and we reserve the right not to respond to requests submitted other than to the email or mailing addresses specified below.

XII. Contact Us

To ask questions or comment or make requests about this Privacy Policy and our privacy practices, contact us at: support@microcaps.com.

Copyright © 2021 by SRAX, Inc. All rights reserved.