Asterra values your privacy. This privacy policy explains what personal data we collect from you and how we use it. This privacy policy applies if you visit or use Asterra's websites or mobile applications (collectively, the "Advisor Platform"). This privacy policy also applies if you visit Asterra's social media or other web pages located on third-party websites.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must contact us and request deletion of your data.
What does Asterra do?
Asterra provides a platform that enables its members to find and connect with an advisor, of whom the member may ask questions or request advice or services directly from the advisor (the "Advisor Platform"). Asterra, via the Advisor Platform, enables a member to communicate directly with the advisor and pay for the advisor's services.
What information and data does Asterra collect about you?
When you visit or communicate on the Advisor Platform, we may collect certain information from you, including but not limited to:
• Information you provide to us, such as:
o Personal information, such as your name and contact information.
o Transcripts and recordings of your communications with advisors, members, and us.
o Responses to surveys that we send and that you respond to.
o Information you provide on Asterra message boards.
o Your payment information, including credit card number(s) and related billing information.
o Any personal information you choose to share through your use of the Advisor Platform, such as your health (physical and/or mental) information, sexual orientation, etc. Please note that if you do not wish to disclose this information, you should not do so.
o For Advisors, applicable tax forms.
• System-generated data, such as:
o Your web browser and usage information, including IP (Internet Protocol) address, browser types, page view tallies, time spent on each page, page browsing information, operating system and type of device used.
• Information shared by our affiliates, such as:
o Any personal information you provide when you use the services of one of our affiliates and that they share with us (as discussed in the "How does Asterra share the data it collects" section of this privacy policy).
How does Asterra collect data and information from you?
We collect information when you sign up to use the Advisor Platform and also when you communicate with other members of the Advisor Platform, including through:
• Asterra's registration process.
• Chats in which you participate.
• Phone calls in which you participate.
• Messages that you send or receive.
• Message boards that you participate on.
• If you register for the Advisor Platform via a third-party social media platform, we may receive information from that third-party platform about you.
• If you are referred to the Advisor Platform through an affiliate or referral partner, we may receive information from such partners about you.
• If you sign up as an Advisor, although Asterra is not responsible for vetting Advisors, we may use a third party to confirm your credentials, including relevant licenses and certifications.
Please note that if we receive your information from third parties as mentioned above, the data you provide to such third parties is also subject to the third party's privacy policy.
In addition, we may collect information through the following methods if you use the Advisor Platform or visit Asterra's social media pages or other pages located on third-party websites:
o Your communications with Asterra,
o Your requests for information, news and other content,
o A technical support request you submit, or
o Your participation in a Asterra promotion.
We may also collect information from our direct interactions with you, publicly available data or data provided by third-party sources, such as marketing opt-in lists.
How and for what purposes does Asterra use the data and information it collects about you?
ASTERRA BEARS NO RESPONSIBILITY FOR THE SECURITY OF YOUR DATA BEYOND REASONABLE MEASURES TAKEN TO PROTECT IT.
Asterra uses the information it collects to provide and improve its services, to deliver information requested by you (for example in response to technical support requests), to deliver marketing or other materials to you (including through phone calls if you provide your telephone number), or for promotions that you may enter. We process your information if you have given your consent; if it's necessary to perform a contract with you or to take steps at your request prior to entering into a contract; if it's necessary to comply with legal obligations; or if it's necessary for us or a third party to pursue a legitimate interest. Asterra may retain your information for a period of time consistent with the original purpose of collection. For example, Asterra may retain your information during the time in which you have an account to use the Services. We may also retain your information during the period of time needed for Asterra to pursue its legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements, and we may delete your information when we no longer require it for our legitimate business purposes.
We may also anonymize your information so that it cannot be associated with you or any other individual. We may analyze and use anonymized data to conduct research and develop new tools, features, products or services. We may also safely share anonymized data with third parties including our affiliates.
How does Asterra use cookies?
Asterra may use cookies and other identification technologies for record keeping purposes and to enhance your experience on the Advisor Platform.
Cookies:
Cookies are small text files stored on a visitor's web browser and applications. Cookies are often used to make web-browsing easier by performing functions such as saving passwords and maintaining lists of personal preferences regarding the use of the website.
The Advisor Platform may use the following types of cookies:
• Strictly Necessary Cookies - these cookies are essential to enable you to browse the Advisor Platform and use the available features.
• Performance Cookies - these cookies collect information about how you use the Advisor Platform. For instance, these cookies track which pages you visit most. This data may be used to help optimize the Advisor Platform and make it easier for you to navigate within them. These cookies do not collect information that identifies you; all information is aggregated and anonymous.
• Functionality Cookies - these cookies allow the Advisor Platform to remember choices you make while browsing, such as geographic location and preferences such as text size and fonts. The information collected by these cookies will not personally identify you.
Other identification technologies that may be used by the Advisor Platform:
• Pixel tags (also called beacons or pixels) - these are small blocks of code installed on (or called by) a webpage or application, which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, website visited, time of visit, referring website, IP address and other similar information.
• Software Development Kits (also called SDKs) - function like pixels and cookies, but operate in the mobile application context where pixels and cookies cannot always function. The application developer can install pieces of code (the SDK) into the application to collect certain information about user interaction with the application and information about the user device and network information.
How does Asterra share the data it collects
Asterra does not sell, trade or rent personal data provided by you in any transcript, survey or recording for direct marketing or any other purpose, except as provided in this privacy policy or with your permission. Asterra does not disclose the contents of transcripts, surveys or recordings other than to service providers performing services on behalf of Asterra, other than as provided in this privacy policy or with your permission.
For legal reasons
We may share your information if we reasonably believe that it: (i) is necessary to comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is necessary to enforce this privacy policy or our Terms of Use or any other agreement in place between you and Asterra; (iv) is necessary to investigate and prevent unauthorized transactions or other illegal activities; and/or (v) is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person or entity.
How can I review, correct or request to delete my personal data?
If you elect to engage in any communication session on the Advisor Platform, it is up to you to decide what, if any, information to provide during such session. Depending on your request, it may not be possible for us or Advisors to fully provide all requested services to you. Nevertheless, if you do not wish to provide certain information, then you should not do so.
If you have signed up to receive Asterra's marketing or advertising communications, you may, at any time, opt out of receiving further communications by clicking on the opt-out link at the bottom of a marketing or advertising email you receive. You may also contact us at info@asterra.com to opt out or to request changes to your personal data.
You may view your communication history on the Advisor Platform by logging in and accessing your account page.
You may request to review, correct, delete, transfer, or receive a copy of any of the personal data you've provided to us through the Advisor Platform or withdraw your consent to Asterra processing your personal data by contacting us at info@asterra.com and we will respond within 30 days. In certain instances, we may determine we have a legitimate interest in not deleting your personal data for a period of time. You may generally update your account settings, user profile, and billing information by logging in to your account.
If you believe that we have not been able to assist you with your inquiry, and you are located in the European Economic Area or the United Kingdom, you have the right to file a complaint with the relevant supervisory authority.
How does Asterra keep my data and information secure?
We use security measures designed to protect against the loss, misuse and alteration of the information under our control, although data transmissions over the internet cannot be guaranteed to be absolutely secure. Your personal information is encrypted during transmission. In addition, transcripts that we store are maintained and archived on secure, hardened servers that are hosted on highly secure data centers. Access to this data is protected by multiple layers of controls, including firewalls, role-based access controls, authentication mechanisms and monitoring. Data is backed up, and archives are stored off-site in a secure location. You may review your chat history and see transcripts of chats you have engaged in. You are only granted access to the chats you engaged in under your profile. Chat history and transcripts are not stored indefinitely.
International data transfers
If you are located outside of the European Union, please note that we may transfer your personal data outside your country of origin. By providing or making available your personal data, you consent to that transfer. We will take steps to ensure that your data is subject to appropriate safeguards required under this privacy policy, applicable data protection laws, and appropriate legally recognized data transfer adequacy mechanisms such as the European Commission-approved standard contractual clauses related to transfers of personal data outside of the EU. Any inquiries or complaints regarding our data privacy practices may be directed to info@asterra.com. We will respond within a reasonable period of time. You also have the right to file a complaint with the appropriate supervisory authority in your jurisdiction.
Minors under Age 16
The Advisor Platform is not directed to individuals under 16. If you are under the age of 16, you may not use or register for the Advisor Platform or provide any personal data to us. Asterra does not knowingly collect personal data from individuals under the age of 16. If you are a parent of an individual under 16 and believe your child has provided personal data to Asterra, please contact us at info@asterra.com, where you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. Asterra reserves the right to immediately terminate any member's account and delete his or her information if it believes the member is under the age of 16.
Changes to this Privacy Policy
We recommend that you review this privacy policy periodically, as we may update it from time to time. Your use of the Advisor Platform, as applicable, constitutes your consent to the new privacy policy to the fullest extent permitted by law.
We are not responsible for and do not control the privacy practices of any of our customers or any other third party. We encourage you to review the privacy practices of each third party.
We welcome your feedback on our privacy policy. Please send any comments or questions to info@asterra.com or via mail to our headquarters address:
Asterra Inc. 195 Arch. Makariou III Ave, Neocleous Tower, 3030 Limassol, Cyprus
Effective as of: 1 May 2025