Owner and Data Controller  

KTR Capital LLC
10 Dominion street 78275 San Antonio Texas 

Owner contact email: raulmoran@ktrcapital.org

Types of Data collected  

Among the types of Personal Data that this Application collects, by itself or  through third parties, there are: Usage Data; first name; last name; date of birth;  email address; username; country; state; payment info; Tracker; answers to  questions; clicks; keypress events; motion sensor events; mouse movements;  scroll position; touch events. 

Complete details on each type of Personal Data collected are provided in the  dedicated sections of this privacy policy or by specific explanation texts  displayed prior to the Data collection. 

Personal Data may be freely provided by the User, or, in case of Usage Data,  collected automatically when using this Application. 

Unless specified otherwise, all Data requested by this Application is mandatory  and failure to provide this Data may make it impossible for this Application to  provide its services. In cases where this Application specifically states that some  Data is not mandatory, Users are free not to communicate this Data without  consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome  to contact the Owner. 

Any use of Cookies – or of other tracking tools – by this Application or by the  owners of third-party services used by this Application serves the purpose of  providing the Service required by the User, in addition to any other purposes  

described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or  shared through this Application and confirm that they have the third party’s  consent to provide the Data to the Owner. 

Mode and place of processing the Data  

Methods of processing  

The Owner takes appropriate security measures to prevent unauthorized access,  disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools,  following organizational procedures and modes strictly related to the purposes 

indicated. In addition to the Owner, in some cases, the Data may be accessible  to certain types of persons in charge, involved with the operation of this  Application (administration, sales, marketing, legal, system administration) or  external parties (such as third-party technical service providers, mail carriers,  hosting providers, IT companies, communications agencies) appointed, if  necessary, as Data Processors by the Owner. The updated list of these parties  may be requested from the Owner at any time. 

Legal basis of processing  

The Owner may process Personal Data relating to Users if one of the following  applies: 

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having  to rely on consent or any other of the following legal bases. This, however,  does not apply, whenever the processing of Personal Data is subject to  European data protection law; 
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that  applies to the processing, and in particular whether the provision of Personal  Data is a statutory or contractual requirement, or a requirement necessary to  enter into a contract. 

Place  

The Data is processed at the Owner’s operating offices and in any other places  where the parties involved in the processing are located. 

Depending on the User’s location, data transfers may involve transferring the  User’s Data to a country other than their own. To find out more about the place 

of processing of such transferred Data, Users can check the section containing  details about the processing of Personal Data. 

Users are also entitled to learn about the legal basis of Data transfers to a  country outside the European Union or to any international organization  governed by public international law or set up by two or more countries, such as  the UN, and about the security measures taken by the Owner to safeguard their  Data. 

If any such transfer takes place, Users can find out more by checking the  relevant sections of this document or inquire with the Owner using the  information provided in the contact section. 

Retention time  

Personal Data shall be processed and stored for as long as required by the  purpose they have been collected for. 

Therefore: 

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. 
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests  pursued by the Owner within the relevant sections of this document or by  contacting the Owner. 

The Owner may be allowed to retain Personal Data for a longer period whenever  the User has given consent to such processing, as long as such consent is not  withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a  longer period whenever required to do so for the performance of a legal  obligation or upon order of an authority. 

Once the retention period expires, Personal Data shall be deleted. Therefore, the  right of access, the right to erasure, the right to rectification and the right to data  portability cannot be enforced after expiration of the retention period.

The purposes of processing  

The Data concerning the User is collected to allow the Owner to provide its  Service, comply with its legal obligations, respond to enforcement requests,  protect its rights and interests (or those of its Users or third parties), detect any  malicious or fraudulent activity, as well as the following: Handling payments and  SPAM protection. 

For specific information about the Personal Data used for each purpose, the  User may refer to the section “Detailed information on the processing of  Personal Data”. 

Detailed information on the processing of Personal Data  Personal Data is collected for the following purposes and using the following  services: 

• Handling payments
• SPAM protection

The rights of Users  

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following: 

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. 
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section  below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. 
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. 
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. 
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted  to another controller without any hindrance. This provision is applicable  provided that the Data is processed by automated means and that the  processing is based on the User’s consent, on a contract which the User  is part of or on pre-contractual obligations thereof. 
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing  

Where Personal Data is processed for a public interest, in the exercise of an  official authority vested in the Owner or for the purposes of the legitimate  interests pursued by the Owner, Users may object to such processing by  providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for  direct marketing purposes, they can object to that processing at any time  without providing any justification. To learn, whether the Owner is processing  Personal Data for direct marketing purposes, Users may refer to the relevant  sections of this document. 

How to exercise these rights  

Any requests to exercise User rights can be directed to the Owner through the  contact details provided in this document. These requests can be exercised free  of charge and will be addressed by the Owner as early as possible and always  within one month.

Cookie Policy  

This Application uses Trackers. To learn more, the User may consult the Cookie  Policy. 

Additional information about Data collection and  processing  

Legal action  

The User’s Personal Data may be used for legal purposes by the Owner in Court  or in the stages leading to possible legal action arising from improper use of this  Application or the related Services. 

The User declares to be aware that the Owner may be required to reveal  personal data upon request of public authorities. 

Additional information about User’s Personal Data  

In addition to the information contained in this privacy policy, this Application  may provide the User with additional and contextual information concerning  particular Services or the collection and processing of Personal Data upon  request. 

System logs and maintenance  

For operation and maintenance purposes, this Application and any third-party  services may collect files that record interaction with this Application (System  logs) use other Personal Data (such as the IP Address) for this purpose. Information not contained in this policy  

More details concerning the collection or processing of Personal Data may be  requested from the Owner at any time. Please see the contact information at the  beginning of this document. 

How “Do Not Track” requests are handled  

This Application does not support “Do Not Track” requests. 

To determine whether any of the third-party services it uses honor the “Do Not  Track” requests, please read their privacy policies. 

Changes to this privacy policy  

The Owner reserves the right to make changes to this privacy policy at any time  by notifying its Users on this page and possibly within this Application and/or –  as far as technically and legally feasible – sending a notice to Users via any  contact information available to the Owner. It is strongly recommended to check  this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the  User’s consent, the Owner shall collect new consent from the User, where  required.