§1 Use of Information

1. Tecra collects non-personally identifiable information from Pioneer regarding Pioneer usage of the Service (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may include, without limitation, Site pages viewed, websites visited before visiting the Site, frequency of visits, clickstream data, browser type, operating system, organization name, internet connection speed, presentations and videos viewed, time spent viewing pages of the Service or using certain features of the Service, demographic data such as server locations, clickstream data, location services, server location, cookies existing on Pioneer’s computer, search criteria used and results, date and time of access or visits to our Site, frequency of visits to the Service, connection speed, and other information which does not specifically identify Pioneer. Tecra collects this information using various technologies (some of which are described below), including, but not limited to, cookies, web beacons, web session variables, server log files, clear gifs, browser plug-ins or add-ons, or Javascript. “Cookies” are pieces of information that may be placed on Pioneer computers by the Service for the purpose of facilitating and enhancing Pioneer communication and interaction with the Service. A “web beacon,” or “Internet tag” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on the Service or in an email which allows a website to record the simple actions of the Pioneer opening the Service that contains the beacon. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction Pioneer conducts with the server.

2. Tecra also collects personal information from Pioneer (“Personally Identifiable Information”) when Pioneer sign up for an account, send an email through the Service, sign up for or purchase a service through the Service, or make an investment through the Service.  Personally Identifiable Information refers to non-public information that identifies Pioneer (such as name, password, age and date of birth, gender, email address, postal mailing address, home/mobile telephone number, social security number/taxpayer identification number, driver’s license number, passport number, Internet protocol (“IP”) address, or other similar identifiers that permit the physical or online identification of a specific individual. Tecra request that Pioneer provide Tecra with other personal information, including, but not limited to, Pioneer personal or company social media profile, demographic information, financial information about issuers (i.e. valuations, share prices, fundraising goals), financial information about individuals (i.e. net worth) and other information requested from time to time. Tecra may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on Pioneer computer or device using mechanisms such as browser web storage or application data caches.  However, not all Non-Personally Identifiable Information and Personally Identifiable Information is stored.

3. Tecra may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on Pioneer interactions with the Service. Google Analytics collects information including, but not limited to, the time of each Pioneer visit to the Service, whether Pioneer has visited the Service before, what website referred you to the Service and what pages Pioneer viewed on the Service.

4. Privacy Policy does not cover the collection of information by cookies or other methods by such Third Party Services or other third parties, such as Tecra business partners. Tecra does not control how these Third Party Services or third parties collect information or by what means such Third Party Services or third parties may use their own cookies to collect information about Pioneer.

5. Tecra will use information that Pioneer provides consistent with this Privacy Policy. Tecra will use information that Pioneer provides, including Non-Personally Identifiable Information or Personally Identifiable Information, to better serve Pioneer and enhance Pioneer experience with the Service. This may include having to modify or copy such Non-Personally Identifiable Information or Personally Identifiable Information, or other information such as images or textual content Pioneer provides, in order to provide Pioneer with a seamless and enjoyable experience.

6. Pioneer consent to use and disclosure of any information submitted to or collected by Tecra via use of the Service, and Pioneer acknowledges that Pioneer has no expectation of privacy, confidentiality or privilege in such information unless as provided by law.

7. Tecra may gather the Registered User from European Union personal data and their processing is done in line with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”).

7.1. The personal data controller is ENZO VENTURES LLC, 6628 Sky Pointe Dr. Ste 129-1215, Las Vegas, 89131, NV, USA entered in the register of business companies as no. 2023-001203529 (hereinafter referred to as: “the Controller” or “Tecra”).

7.2. Controller contact details:

·     Address for correspondence: United Race LLC 6628 Sky Pointe Dr. Ste 129-1215, Las Vegas, 89131, NV, USA

·      Email address: [email protected].

8. If you are a European Union user, you can contact Tecra representative: [email protected].

9. Basis for processing the data:

10. Tecra may use Non-Personally Identifiable Information and Personally Identifiable Information:

a). to market Tecra products and services to Pioneer;
b). to provide services and products requested by Pioneer;
c). to provide targeted advertisements and messages on the Service to Pioneer or other users of the Service;
d). to enable Tecra vendors and contractors to provide and assist in the marketing, operation, troubleshooting and analysis of the Service and other services;
e). to conduct research and analyze data to improve our products, services, and Site;
f). to deliver special offers, updates, newsletters, customer service, and service announcements to Pioneer and other users;
g).  to verify Pioneer’s information;
h). to comply with any regulatory requirements for the offer or sale of tokens required by law, rules or regulations to Tecra affiliates or members;
i). to protect the Service or its Pioneers;
j). to engage in any other lawful business activities that are consistent with the foregoing;
k). as required by or to comply with law or Tecra’s policies or to protect Tecra from legal liability. Tecra may provide any of these services through third parties, which may necessitate sharing Non-Personally Identifiable Information or Personally Identifiable Information with them.

11. Sharing of data:

a. Partners whose services are used by Tecra to provide services to Users may access User’s data as necessary. In such cases, Tecra has entered into appropriate data entrustment agreements with such partners, in order to secure Users' data against unauthorized access.

b. Users and associates of Tecra may also access the User's data in the scope of performing their official duties. In such a situation, these persons act on the basis of an appropriate authorization and are obliged to keep the data confidential.

12. The User has the following rights in relation to personal data processed by Tecra:

a. The right to access personal data: At the User's request, Tecra will confirm what personal data of the Users it processes and provide a copy of this data.

b. The right to rectify personal data: In the event that the User's personal data is incorrect or incomplete, the User may require Tecra to correct or supplement it.

c. The right to delete personal data: In certain situations, the Users may require Tecra to delete personal data processed by Tecra.

d. Users may request Tecra to temporarily suspend processing of data. Despite the processing restrictions, Tecra will still be entitled to store personal data.

e. The right to request the transfer of personal data: In specific Users also have the right to receive personal data processed by Tecra in a structured, commonly used machine-readable format to transfer this data to another controller.

f.  The right to withdraw consent. Withdrawal of consent does not affect the correctness of the processing of personal data on the basis of previously expressed consent.

g. Right to object to the processing of personal data: Users may demand discontinuation of processing of personal data by Tecra when Tecra processes personal data on the basis of a legitimate interest either its own or a third party’s, except in situations where these interests are inferior to the interests, rights and freedoms of the User, User's data are processed for direct marketing purposes.

h. The user has the right to file a complaint with the data protection authority.

13.  Data which may be shared or transferred

The personal data collected and generated by Tecra during its operation within the territory of the EU shall be stored within the territory of EU. If Tecra needs to transfer Users personal data abroad, Tecra shall obtain prior consent and conduct the cross-border data transfer in accordance with the GDPR, regulations and policies and undertake the confidentiality obligations to protect your personal data.

14. Data retention periods

a. Tecra stores Users' personal data only for the time that is necessary to achieve the purposes for which the data was collected. After this time, the data is deleted or anonymized in such a way that it is impossible to determine the identity of the User. Personal data may be stored longer if such an obligation arises from the provisions of law or it is necessary to defend or assert by Tecra claims against Users.

b. In the event of withdrawal of consent, the data will be deleted, unless there is another legal basis for their processing.

§2 Third Party Services

1. Tecra may make Pioneer information, including Non-Personally Identifiable Information or Personally Identifiable Information, available on the Service and visible to other Pioneers of or visitors to the Service.  For instance, subject to certain preferences and Tecra permissions to visibility Pioneer will be allowed to make, information Pioneer provides about yourself in response to questionnaires on the Service may be made available to others such as information concerning Pioneer status as an accredited investor. As such, other Pioneers of the Service may be able to personally identify Pioneer based on your information made available on the Service. As a further example, if Pioneer utilizes Third Party Services to log into the Service, other Pioneers to whom Pioneer may be connected through such Third Party Service may be able to view or follow information about Pioneer, including Non-Personally Identifiable Information or Personally Identifiable Information, on the Service.

2. Tecra may also employ or contract with other third party partners, companies, or individuals to perform certain functions or services on its behalf.  Examples of these services from such third parties, companies, or individuals, may include ID verification, electronic document signing, payment storing and processing, sending postal mail and email, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service.  As such, these third party partners, companies, or individuals may have access to Pioneer information, including Non-Personally Identifiable Information or Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes.

3. Tecra may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information to help Tecra to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to Tecra business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of the Service or network; to protect and defend Tecra rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of Tecra’s business or assets. Any successor in interest to Tecra business would acquire the information Tecra maintains, including Personally Identifiable Information, and may alter the terms of this Privacy Policy..

4. Except as identified here and subject to Pioneer’s ability to opt-out as provided by Regulation S-P, Tecra does not and will not sell any of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to any third party for purposes of advertising, soliciting, or telemarketing.  Tecra may provide Personally Identifiable Information, including Pioneer’s name, email address, and the date and company of any investment to certain third parties that have referred issuers and investors to Tecra, or to certain Issuers, including but not limited to issuers in which Pioneer have expressed interest. Tecra may also be required to disclose Pioneer information, including Non-Personally Identifiable Information or Personally Identifiable Information, to other companies or entities in the event that Tecra may be sold or is sold to another company or entity.  In that case, Pioneer information, including Non-Personally Identifiable Information or Personally Identifiable Information, may be sold or transferred to such acquiring company or entity.

5. The Service contains links to other websites and services not maintained by Tecra.  In addition, other websites and services may also reference or link to the Service. Tecra encourages Pioneer to be aware when Pioneer enters or leaves the Service or surf the Internet, and to read the privacy statements of each website and service that Pioneer visits.  Tecra do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of other websites or services.

6. The Service permits Pioneers to communicate with companies and other Pioneers posting information on the Service. Tecra may read, collect and analyze information transmitted between Pioneers for regulatory compliance and marketing purposes. Tecra does not guarantee that information provided by Service visitors or investors is accurate or complete. Tecra assumes no liability or responsibility for any errors or omissions in the content of the Service.

§3 Identification and Security

7. Tecra may at times send to Pioneer email communications with information, marketing or promotional materials.  If Pioneer prefers not to receive such emails from Tecra, he may unsubscribe completely by contacting Tecra through the contact by email: [email protected].

8. If Pioneer would like to remove Personally Identifiable Information from Tecra database, please send a request through the email: [email protected].  

9. Tecra is not responsible for removing Pioneer Personally Identifiable Information from the lists of any Third Party Services or other third party partner who has previously been provided your information in accordance with this Privacy Policy.