Privacy Policy

1. Who We Are

Digital ATM ("we," "us," or "our") operates the Digital ATM course platform from the State of Wyoming, United States. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website or purchase our products.

If you have questions about this policy, contact us at support@digitalatmapp.com.

This policy should be read together with our Terms of Service and Earnings Disclaimer.

2. What Personal Data We Collect

We collect the following categories of personal information:

• Identifiers:When you buy our course through JVZoo, your name and email address are collected by JVZoo and transmitted to us via JVZoo's Instant Payment Notification system so we can deliver the product and provide support.
• Financial information: Payment details (credit card number, billing address) are collected and processed exclusively by JVZoo. We do not receive, store, or have access to your full payment card information.
• Email address: If you subscribe to our email list, we collect your email address to send you course updates and, with your consent, marketing communications. Your email is stored with our email service provider.
• Internet activity data: Our website automatically collects your IP address, browser type, device type, operating system, pages visited, time spent on pages, referring URL, and click patterns through analytics tools and server logs.
• Cookies and tracking technologies: We and third parties use cookies, pixels, and similar technologies to improve your browsing experience, analyze site traffic, and track marketing effectiveness. See Section 8 below for details.
• Course progress: Your course progress is stored in our database and associated with your account so you can resume across devices. We may also use local browser storage temporarily to queue unsent progress updates.
• Communications: If you email us for support or other inquiries, we retain the content of your messages, your email address, and our responses.

Sensitive personal information: We do not intentionally collect sensitive personal information such as Social Security numbers, government-issued identification numbers, financial account numbers with access credentials, precise geolocation, racial or ethnic origin, religious beliefs, health data, sexual orientation, or biometric data.

3. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you: When you make a purchase, subscribe to our email list, or contact us for support.
• From JVZoo: Our payment processor transmits your name and email address to us after a purchase.
• Automatically from your device: When you browse our website, through cookies, pixels, server logs, and similar technologies.
• From analytics providers: Such as Google Analytics, which provides aggregated and individual usage data about how visitors interact with our site.

4. How We Use Your Data

We use your personal information for the following purposes:

• Deliver the course: To provide access to the course content you purchased and deliver related materials.
• Customer support: To respond to your questions, troubleshoot issues, and provide assistance.
• Marketing communications: To send you emails about course updates, tips, and related products (only with your consent; you can unsubscribe at any time).
• Website improvement: To analyze how visitors use our website so we can improve the user experience, content, and functionality.
• Security and fraud prevention: To protect our website and users from unauthorized access, fraud, and abuse.
• Legal compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Transaction processing: To facilitate refunds, respond to chargebacks, and maintain transaction records as required by tax and accounting law.

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

All marketing emails include our physical mailing address and a one-click unsubscribe link in compliance with the CAN-SPAM Act.

5. Third Parties We Share Data With

We disclose your personal information to the following categories of third parties for the business purposes described below:

• JVZoo (payment processor): JVZoo independently collects and processes your name, email address, and payment information when you make a purchase. JVZoo is an independent data controller and handles your payment data under their own privacy policy. See JVZoo's privacy policy for details.
• JVZoo affiliates:If you purchased our course through an affiliate's referral link, that affiliate may receive your name and email address through the JVZoo platform for purposes of providing you with bonus materials or follow-up support. JVZoo's affiliate practices are governed by their own terms and privacy policy.
• Email service provider: We use a third-party email service to send marketing emails and course updates. Your email address is shared with this provider solely for email delivery purposes.
• Analytics providers: We use services such as Google Analytics and PostHog to understand how visitors use our site. These services collect usage data including IP addresses, browser information, and browsing behavior. PostHog also records anonymized session replays (with all form inputs masked) to help us improve the learning experience. Google Analytics may use this data in accordance with Google's Privacy Policy. PostHog's privacy policy is available at posthog.com/privacy.
• Hosting provider (Vercel): Our website is hosted on Vercel. Vercel may process server logs containing your IP address, browser type, and request data as part of delivering our website to you.

We do not sell your personal information to third parties. We do not share your personal information for cross-context behavioral advertising purposes.

Third parties, including analytics providers and our payment processor, may collect information about your online activities over time and across different websites when you use our site. Please refer to these third parties' own privacy policies for details on their data practices.

We may disclose personal information if required by law, subpoena, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Business transfers: In the event of a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you via email or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

6. How We Protect Your Data

We take reasonable administrative, technical, and physical measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include using HTTPS encryption for all data transmitted between your browser and our servers, limiting access to personal information to authorized personnel, and selecting service providers who maintain appropriate security practices.

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

7. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes described in this policy, provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Purchase records (name, email, transaction ID): Retained for 3 years after your last transaction or as long as required by tax and accounting law (whichever is longer).
• Marketing email addresses: Retained until you unsubscribe. Upon unsubscription, your email is moved to a suppression list to ensure we do not contact you again.
• Support communications: Retained for 2 years after the last communication.
• Analytics data:Retained in accordance with our analytics provider's default settings (typically 14–26 months for Google Analytics).
• Server logs: Retained by our hosting provider for up to 30 days.
• Course progress data: Retained while your account is active so your learning history is available across sessions and devices. If you request account deletion, we delete or anonymize this data subject to applicable legal requirements.

When data is no longer needed for any of the above purposes, we delete or anonymize it. You may request deletion of your data at any time (see Your Rights sections below).

8. Cookies and Tracking Technologies

Our website uses cookies (small text files stored on your device) and similar tracking technologies. Here is what we use and why:

Types of Cookies We Use

• Strictly necessary cookies: Required for the website to function. These cannot be disabled. They include cookies that remember your session and enable basic navigation.
• Analytics cookies: Help us understand how visitors use our website by collecting information about pages visited, time spent, and navigation patterns. We use Google Analytics and PostHog for this purpose.
• Marketing/tracking cookies: Used by our payment processor (JVZoo) to track affiliate referrals and attribute sales. These are set by JVZoo, not by us.

Third-Party Cookies

Our payment processor (JVZoo) and analytics providers may set their own cookies on your device. JVZoo uses cookies to track affiliate referrals and attribute sales. Google Analytics and PostHog use cookies to collect usage data. These third-party cookies are governed by their respective privacy policies. We do not control these cookies.

How to Control Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. You can also opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. To opt out of PostHog analytics and session recording, click the button below. Disabling cookies may affect some features of our website.

Do Not Track and Global Privacy Control

We honor Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we treat it as a valid opt-out request for the sale or sharing of your personal information, as required by California, Colorado, and Connecticut law.

We also recognize Do Not Track (DNT) browser signals. When we detect a DNT signal, we disable non-essential analytics and marketing cookies for your session.

9. Your Privacy Rights: All Users

Regardless of your location, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct inaccurate or incomplete data.
• Deletion: Request that we delete your personal data, subject to legal retention obligations.
• Opt-out of marketing: Unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email.

To exercise any of these rights, email us at support@digitalatmapp.com. To protect your privacy, we may need to verify your identity before processing your request. We will not discriminate against you for exercising any of your privacy rights.

10. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). This section provides the disclosures required by California law.

Categories of Personal Information We Collect

We do not collect categories C (protected classifications), E (biometric information), H (sensory data), I (professional or employment information), J (education information), K (inferences), or L (sensitive personal information) as defined by the CCPA.

Sale and Sharing of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. We have not sold or shared personal information in the preceding 12 months.

Your California Rights

As a California resident, you have the right to:

• Right to know: Request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties with whom we shared it.
• Right to delete: Request that we delete personal information we have collected from you, subject to certain exceptions (e.g., completing a transaction, legal compliance, security).
• Right to correct: Request that we correct inaccurate personal information we maintain about you.
• Right to opt-out of sale or sharing: Although we do not sell or share your personal information, you have the right to direct us not to do so. We honor this right automatically.
• Right to limit use of sensitive personal information: We do not collect sensitive personal information beyond what is necessary to provide our services.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge you different prices, provide a different quality of service, or retaliate in any way.

How to Submit a Request

You may submit a request to exercise your California privacy rights by:

• Emailing us at support@digitalatmapp.com with the subject line "California Privacy Request"
• Mailing a written request to: Digital ATM, 1712 Pioneer Ave, Suite 500, Cheyenne, WY 82001, United States

Verification Process

To protect your privacy, we will verify your identity before fulfilling any request. For requests to know or delete, we will ask you to provide at least two pieces of personal information that match our records (such as the email address associated with your purchase and your transaction ID or date of purchase). We will confirm receipt of your request within 10 business days. We will respond to your request within 45 calendar days. If we need more time (up to an additional 45 calendar days), we will notify you in writing and explain the reason for the extension.

Authorized Agents

You may designate an authorized agent to submit a request on your behalf. If you use an authorized agent, we may require the agent to provide proof of written authorization from you, and we may still verify your identity directly. We will not process requests from agents who cannot demonstrate proper authorization.

Financial Incentives

We do not offer financial incentives or price differences in exchange for the retention or sale of your personal information.

Minors Under 16

We do not knowingly collect or sell the personal information of consumers under the age of 16. Our course is intended for adults aged 18 and older.

California "Shine the Light" Law

Under California Civil Code Section 1798.83, California residents may request information about personal information we disclosed to third parties for direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

11. Additional US State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Iowa, Nebraska, Tennessee, Indiana, Kentucky, Minnesota, Maryland, or any other state with a comprehensive consumer privacy law, you may have similar rights to those described in the California section above, including:

• The right to confirm whether we are processing your personal data
• The right to access your personal data
• The right to correct inaccuracies in your personal data
• The right to delete your personal data
• The right to obtain a portable copy of your personal data
• The right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

To exercise any of these rights, email us at support@digitalatmapp.com. We will respond to your request within 45 calendar days. If we need more time, we will notify you of an extension of up to 45 additional calendar days (or up to 60 additional calendar days where permitted by your state's law). If your request is denied, you have the right to appeal our decision by emailing us with the subject line "Privacy Rights Appeal." We will respond to appeals within the timeframe required by your state's law. If you are not satisfied with our response to your appeal, you may contact your state's attorney general.

We honor Global Privacy Control (GPC) signals as a valid opt-out request under all applicable state privacy laws.

12. Your Rights Under GDPR (European Economic Area, United Kingdom, and Switzerland)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) and/or the UK GDPR apply to our processing of your personal data. This section provides the additional information required by those regulations.

Data Controller

Digital ATM is the data controller for the personal data described in this policy. Our contact information is provided in Section 15 below.

Legal Basis for Processing

We process your personal data under the following legal bases:

• Performance of a contract (Art. 6(1)(b)): Processing your name and email to deliver the course you purchased, process refunds, and provide customer support.
• Consent (Art. 6(1)(a)): Sending you marketing emails (you can withdraw consent at any time), setting non-essential cookies, and transferring your data to the United States.
• Legitimate interests (Art. 6(1)(f)): Analyzing website usage to improve our services, maintaining security, and preventing fraud. Our legitimate interests do not override your fundamental rights and freedoms.
• Legal obligation (Art. 6(1)(c)): Retaining transaction records as required by tax and accounting laws.

Necessity of Providing Data

Providing your name and email address is necessary to enter into the contract for course delivery. If you do not provide this data, we cannot deliver the course to you. Providing data for analytics and marketing purposes is voluntary and based on your consent. You are not obligated to provide data for these purposes, and declining will not affect your access to the course.

Your Data Subject Rights

Under the GDPR, you have the following rights:

• Right of access (Art. 15): Request a copy of the personal data we hold about you, along with information about how we process it.
• Right to rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to erasure (Art. 17): Request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when there is no overriding legitimate ground for processing.
• Right to restrict processing (Art. 18): Request that we limit processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing based on legitimate interests.
• Right to data portability (Art. 20): Receive your personal data in a structured, commonly used, and machine-readable format (such as CSV or JSON), and transmit it to another controller.
• Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will stop immediately.
• Right to withdraw consent (Art. 7(3)): Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.
• Right not to be subject to automated decision-making (Art. 22): We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you.

International Data Transfers

Your data is transferred to and processed in the United States. For transfers of personal data from the EEA, UK, or Switzerland to the United States, we rely on your explicit consent under Article 49(1)(a) of the GDPR. Before completing a purchase, you will be presented with a clear notice that your data will be transferred to and processed in the United States, and you will be asked to affirmatively consent to this transfer. You may withdraw this consent at any time by contacting us, though this may affect our ability to provide our services to you.

Where our third-party service providers (such as Google, Vercel, or our email service provider) process personal data outside the EEA, they may rely on Standard Contractual Clauses (SCCs) approved by the European Commission, the EU-US Data Privacy Framework, or other approved transfer mechanisms. We have reviewed and documented the data protection practices of our key service providers.

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by Article 33 of the GDPR. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, as required by Article 34.

Data Protection Officer

We have not appointed a Data Protection Officer as we do not engage in large-scale processing of special categories of data or large-scale systematic monitoring of individuals. For all data protection inquiries, please contact us at support@digitalatmapp.com.

Response Time

We will respond to data subject requests within one calendar month of receipt. If your request is complex or we have received a large number of requests, we may extend this period by up to two additional months. We will notify you of any extension within the first month and explain the reason for the delay.

Right to Complain

You have the right to lodge a complaint with your local supervisory authority if you believe we have violated your data protection rights. A list of EEA supervisory authorities is available at edpb.europa.eu. For the UK, you may contact the Information Commissioner's Office (ICO).

13. Children's Privacy

Our website and products are not directed at children under 18. We do not knowingly collect personal information from children under 16 (or under 13 where the Children's Online Privacy Protection Act applies). If you believe a child has provided us with personal data, please contact us immediately and we will take steps to delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on this page with a new "Last updated" date and, where practical, by email to the address associated with your account. We encourage you to review this page periodically. Previous versions of this policy are available upon request by emailing support@digitalatmapp.com.

15. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your data, contact us at:

Digital ATM
1712 Pioneer Ave, Suite 500
Cheyenne, WY 82001, United States
Email: support@digitalatmapp.com

For California privacy requests, use the subject line "California Privacy Request."
For GDPR data subject requests, use the subject line "GDPR Data Request."
For all other state privacy requests, use the subject line "Privacy Rights Request."