Privacy Policy

1. Introduction 

This website order27qm5.com (the “Site”) has been set up by Inca Digital, in connection with proceedings relating to Case No. 2026-009414-CA-01 - Circuit Court of the Eleventh Judicial Circuit, Miami-Dade County, Florida - Circuit Civil Division. 

The designers of the Site recognize the importance of protecting the privacy of online visitors. This privacy policy (“Privacy Policy”) explains how we collect, use, disclose, share and protect personal data (as defined below) from and about you that we process through your interactions with us, including your interactions with this Site. 

This Privacy Policy contains information on our use of your personal data in accordance with relevant laws and regulations to which we may be subject. 

Please read this Privacy Policy carefully to understand what we do with your personal data. The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law. 

2. Collection of Personal Data 

We may collect nonpublic personal information and other personal information about you, including information that can reasonably be linked directly or indirectly with you (“personal data”). We may collect certain categories of personal data from or about you, including: 

• identifiers, including online identifiers, and similar information, such as blockchain wallet address, IP address, or other similar identifiers; and 

• internet or other electronic network activity information, including interactions with the Site, date and time of visit of the Site, or use of certain online tools. 

3. Sources of Personal Data 

This website may collect personal data directly from you and/or your intermediaries through sources such as interactions with the Site or written, electronic, or verbal correspondence with us or our service providers, including professional service providers. 

We may also collect personal data from different categories of sources, such as: (i) our service providers, including professional service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud. 

In certain circumstances, we may be provided with your personal data in the context of our operations, including in connection with the case(s) applicable to the creation of this website and any related proceedings. 

4. Purposes for Collection and Use of Personal Data 

We may collect, use or process personal data for the purposes of our work in connection with the cases of, and related proceedings regarding, insert the matters, such as: 

• communicating with you; 

• complying with legal or regulatory requirements; 

• performing our contractual and other legal obligations; 

• establishing, exercising or defending legal claims and in order to protect and enforce our (or another person’s) rights, property, or safety, or to assist others to do the same; 

• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; 

• administering and improving our Site; 

• providing you with the information, products, or services you requested; 

• evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets; and 

• internal operations, such as troubleshooting, data analysis, testing, research and statistical purposes. 

We will only use personal data for the purposes for which it has been collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose of the control or processing. If we need to control or process personal data for an unrelated purpose, we will use reasonable endeavors to notify affected persons and to explain the basis on which we are permitted to undertake the same. 

5. Disclosure of Personal Data 

We may share personal data with certain third parties for the purposes set out above, including as follows: 

• We may share your personal data with our service providers to perform the functions for which we engage them. For example, we may share your personal data with professional service providers such as law firms, consultants, and other third parties. We may also use third parties to host the Site or assist us in providing functionality on the Site and provide data analysis and research as regards the Site.

• We may share your personal data with regulatory, legal and tax authorities, including for example to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal data as required to pursue available remedies or limit damages we may sustain. We also may share your personal data with third parties (including, but not limited to, governmental organizations and self-regulatory organizations) to enforce our rights, protect our property or protect the rights, property or safety of others, to prevent fraud, unauthorized transactions or liability; or as needed to support external auditing and compliance functions.

• We may share your personal data with third parties in the context of our operations, including in service of the affiliate matter. 

• We may transfer information, including your personal data, to third parties (including potential acquirers) in connection with a change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part) and where we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). We do not share your personal data with third parties for those third parties’ marketing purposes. 

6. Security and Retention of Personal Data 

We take reasonable steps to use technical, administrative, organizational and physical security measures appropriate to the nature of the personal data we are processing and designed to prevent unauthorized intrusion to the Site and to protect your personal data from unauthorized access, exfiltration, alteration, acquisition, theft, disclosure, or misuse. We generally restrict access to personal data to those employees and agents who have been advised as to the proper handling of such data and who need to know such data to perform their duties. Given the nature of information security, there is no guarantee that such safeguards will always be successful. To the extent permitted under applicable law, we will not be responsible for loss, corruption or unauthorized acquisition or misuse of personal data that you provide through the Site that is stored by us, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse. 

How long we keep your personal data will vary depending on the type of personal data and our reasons for collecting it. The retention period will be determined by various criteria, including the amount, nature and sensitivity of the personal data, the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). In general, we will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying our legal and regulatory obligations. 

7. Additional Information for California Residents 

The California Consumer Privacy Act (“CCPA”) grants certain rights to California residents (“California Resident,” “you” or “your” in this Section) with regard to “personal information,” which may be applicable. If you are a California Resident, please review the following information about our privacy practices surrounding how and why we may collect, use, disclose, and share your personal information and your potential rights with regard to your personal information under the CCPA. The rights described in this Section are subject to exemptions and other limitations under applicable law, and the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to certain federal laws. 

Terms used in this Section have the meaning ascribed to them in the CCPA. “Personal information” as used in this Section has the same meaning as in the CCPA. It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA. 

a. Notice at Collection and Use of Personal Information 

i. Information We Collect: Depending on how you interact with us, we may collect the categories of personal information listed above in Section 2. 

ii. How We Use Collected Information: We may use your personal information for the business or commercial purpose listed above in Section 4. 

For more information about our privacy practices, please review the entirety of this Privacy Notice. 

b. Our Collection, Use, Disclosure, and Sharing of Personal Information 

i. What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information: In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in Section 2. We may have collected personal information from all or some of the categories of sources listed in Section 3. We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in Section 4. 

ii. Our Disclosure and Sharing of Personal Information: We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell personal information of California residents under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described below:

Category of Personal Information: 

Identifiers including online identifiers, and similar information, such as blockchain wallet address, IP address, or other similar identifiers

Internet or other electronic network activity information, including interactions with the Site, date and time of visit of the Site, or use of certain online tools

Category of Third Parties

Counterparties and intermediaries in connection with the affiliated cases of, and related proceedings regarding Insert Matter

Service providers in connection with the functions for which we engage them, including professional service providers such as law firms, consultants, and third parties that host the Site or assist us in providing functionality on the Site and provide data analysis and research as regards the Site. 

Entities who assist with fraud prevention, detection and mitigation as well as the prevention of unauthorized transactions or liability, including credit agencies and to assist with anti-money laundering or anti-terrorism checks. 

Third parties such as governmental organizations and self-regulatory organizations to enforce our rights, protect our property or protect the rights, property or safety of others.

Regulatory, legal and tax authorities, including for example in order to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. 

Third parties as needed to complete our legal and regulatory obligations, and also as required to pursue available remedies or limit damages we may sustain or as needed to support external auditing and compliance functions. 

Third parties in connection with a change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part) and where we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). 

In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified above in Section 2 to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries, or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. 

We may also share your personal information with our service providers such as IT and data storage, cybersecurity, email, back office, due diligence, and sanctions screening database, and compliance management providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA. 

c. California Residents’ Rights under the CCPA 

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: 

be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; 

not be discriminated against because you exercise any of your rights under the CCPA; 

request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); 

opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); 

opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); 

limit the use and disclosure of sensitive personal information (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); 

correct inaccurate personal information (“Right to Correct”); and 

request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with which we disclose personal information about you for a business purpose; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose. 

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation. 

We may ask that you provide clarifying or identifying information to verify a Request to Know or Request to Delete. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only. You may be permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request. We may deliver responses to verifiable consumer requests, free of charge by mail or electronically, at your election. Any response to a Request to Know may only cover the 12-month period preceding the verifiable request. 

8. Additional Information for EEA and UK Data Subjects 

The EU/UK General Data Protection Regulation (the “GDPR”) grants certain rights to data subjects located in the EEA or UK (“data subject,” “you,” or “your” in this Section) in certain circumstances, which may be applicable. “Personal data” and other terms as used in this Section have the same meaning provided in the GDPR. 

Legal Basis:  As described above in Sections 2 and 4, we may process personal data for various purposes. Our lawful bases for processing such personal data include: 

where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

to comply with certain legal and regulatory requirements;

depending on the circumstances, we may need to process your personal data for the performance of a contract to which you are a party, or related pre-contractual steps; and 

with your consent, as required by the GDPR.

Rights Applicable to Certain EEA or UK Data Subjects: Under the GDPR and any other applicable EU or UK data privacy laws, certain data subjects have a right to: 

request access to and rectification of your personal data; 

correct personal data that we hold where it is incomplete or inaccurate;

restrict the processing of your personal data in certain circumstances;

object to the processing of your personal data in certain circumstances, including where we process personal data for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; 

request that we erase your personal data under certain circumstances;

ask for a copy of your personal data to be provided to you, or to a third party, in a digital form; 

withdraw your consent to the processing of your personal data (where applicable); and 

lodge a complaint about the processing of your personal data with your local data protection authority. 

c. Transfers of Personal Data Outside the EEA or the UK: Our activities and the jurisdictions in which we are established are such that it may be necessary for personal data that we obtain from you to be transferred and/or processed outside of the EEA or the UK, chiefly but not limited to the United States. Personal data may be accessible by employees and other persons working on our behalf, located outside of the EEA or the UK, including to certain service providers (including but not limited to technical service providers and electronic data storage providers) who may process the information you give us. In circumstances where we transfer personal data outside the EEA or the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, personal data is generally transferred only to persons in countries outside the EEA or the UK in one of the following circumstances:

to persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the relevant Secretary of State in the United Kingdom, as applicable (an “adequacy decision”); 

to persons and undertakings based in the United States if they are part of the EU-U.S. Data Privacy Framework which requires them to provide similar protection to personal data shared between the EEA and the United States, as well as between the UK and the United States pursuant to the Data Protection (Adequacy) (United States of America) Regulations 2023 for the UK Extension to the EU-U.S. Data Privacy Framework (the UK-US Data Bridge); 

to persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the European Commission or in the form of the international data transfer agreement adopted by the Information Commissioner’s Office and the UK Parliament or an equivalent or replacement agreement (the IDTA), as applicable, and as supplemented where and if required; 

to persons and undertakings outside of the EU or the UK pursuant to other appropriate safeguards for the transfer of personal data; and 

only on one of the conditions allowed under the GDPR in the absence of an adequacy decision or appropriate safeguards. 

9. Cookies and Similar Technologies 

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website. Our Site may use cookies for various purposes, including to distinguish you from other users of our website and collect certain information about your interactions with our website. This may help us, among other things, to improve our Site and comply with legal and regulatory obligations. Some web browsers may transmit “do not track” (“DNT”) signals. We currently do not respond to DNT settings in your web browser. 

10. Links to External Websites 

Our Site may contain links to third party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third-party websites, and we are not responsible for the information practices of such third party websites.

11. Children 

Our services are not directed at individuals under the age of 18. We do not knowingly solicit or collect personal data from children under the age of 18. If we become aware that a child under 18 has provided us personal data, we will delete such data from our files. 

12. Changes to this Privacy Policy 

We may update this Privacy Policy from time-to-time and any changes to our Privacy Policy will be posted to this page. Accordingly, please refer back to this Privacy Policy frequently as it may change.

For questions relating to this policy, please contact: privacy@inca.digital