Privacy Policy 

Last Updated: October 21st, 2025 

At NXTMOVES, your privacy and the security of any information you share with us are of utmost importance. This Privacy Policy for NXTMOVES, Inc. (“we”, “us”, or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

  • Visit our website, or any website of ours that links to this Privacy Policy
  • Download and use our mobile application (ROOK), or any other application of ours that links to this Privacy Policy
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or Concerns?

Reading this Privacy Policy will help you understand your privacy rights and choices.  We are responsible for making decisions about how your personal information is processed.  If you do not agree with our policies and practices, please do not use our Services.

Types Of Information We Collect

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the product features you use.  The personal information we collect may include the following:

  • Names
  • Phone Numbers
  • Email Addresses
  • Mailing and/or Billing Addresses
  • Job Titles
  • Usernames
  • Passwords
  • Contact Preferences
  • Contact or authentication data
  • Debit/Credit Card Numbers
  • Bank Account Numbers

Sensitive Information.  When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • Financial data
  • Biometric data
  • Credit worthiness data
  • Social security numbers or other government identifiers

Payment Data.  We may collect data necessary to process your payment, such as your payment account number and, if applicable, the security code associated with your payment account.  

Application Data.  If you use our application(s), we also may collect the following information if you choose to provide us with access or permissions:

  • Geolocation information.  We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services.  If you wish to change our access or permissions, you may do so in your device’s settings.
  • Derivative Data.  Information our servers automatically collect when you access the platform, such as your native actions that are integral to the platform, including questions to NXTMOVES Advisors, reviews, as well as other interactions with the platform and other users via server log files.
  • Mobile Device Data.  Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.  We may request access to certain features from your mobile device, including your device’s storage.  
  • Push Notifications.  We may request to send you push notifications regarding your account or the platform. If you  wish to opt-out from receiving these types of communications, you may turn them off in your  device’s settings. 
  • Website Analytics.  We may also partner with selected third-party vendors, such as Adobe Analytics, Google Analytics and others, to allow tracking  technologies and remarketing services on the platform through the use of first party  cookies and third-party cookies, to, among other things, analyze and track users’ use of the platform, determine the popularity of certain content, and better understand online activity. By accessing the platform, you consent to the collection and use of your  information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer  personal information to these third-party vendors. You should be aware that getting a new computer, installing a new browser, upgrading an existing  browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt out cookies, plug-ins, or settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected from other sources.  In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources such as public databases, joint marketing partners, affiliate program, data providers, and from other third parties.  This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

How We Use The Information We Collect

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts.  We may process your information so you can create and log into your account, as well as keep your account in working order including keeping information updated, accessing information, submitting inquiries and making payments.
  • To communicate with you regarding Services.  We may process your information so we can contact you regarding Services including, but not limited to, activity, important dates such as due dates or expiration dates, solicitation of feedback regarding Services, support and troubleshooting and to mitigate fraudulent activity.
  • To compile anonymous statistical data and analysis.  We may process some of your information to identify patterns and anomalies in an effort to obtain insight, prevent fraud and identify criminal activity.
  • For our own business purposes.  We may process your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.  This is not considered to be “selling” of your personal information.

When And With Whom Do We Share Your Personal Information?

Vendors, Consultants, and Other Third-Party Service Providers.  We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work.  We have contracts in place with our third parties, which are designed to help safeguard your personal information.  This means that they cannot do anything with your personal information unless we have instructed them to do it.  They will also not share your personal information with any organization apart from us.  They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

  • Communication & Collaboration Tools
  • Finance & Accounting Tools
  • Financial Institutions
  • Payment Processors
  • Data Analysis & Fraud Mitigation Entities

We also may need to share your personal information in the following situations:

  • Business Transfers.  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates.  We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.  Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners.  We may share your information with our business partners to offer you certain products, services, or promotions.

Legal and Regulatory Entities.  We may share your data with legal entities, such as law enforcement, as well as regulatory agencies, such as the Federal Trade Commission and the Consumer Financial Protection Bureau and Card Networks, such as Visa, Mastercard, Discover and American Express.  If we believe the release of information about you is necessary to respond to legal processes, investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

Marketing Communications.  With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law. 

Social Media Contacts.  If you connect to the platform through a social network, your contacts on the social network  will see your name, profile photo, and descriptions of your activity. 

We are not responsible for the actions of third parties with whom you share personal or sensitive  data, and we have no authority to manage or control third-party solicitations. If you no longer wish  to receive correspondence, emails or other communications from third parties, you are  responsible for contacting the third party directly. 

Online Tracking And Advertising

We and certain trusted service providers operating on our behalf collect information about your activity on the Services using tracking technologies, including:

  • Cookies.  - See definition and use in NXTMOVES Cookie Policy - 

You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device Settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient and some of the Services will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.

  • Pixel tabs, web beacons, clear GIFs and other similar technologies.  These are typically small pieces of data that are embedded in images on the Website, our Applications or certain email communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use these technologies to bring together information we collect about you.
  • Location tracking on mobile devices. Certain applications on mobile devices may transmit information to us about your location. An includes your physical location when you search for a nearby ATM using your mobile device. We may use that information to improve the products and services we provide to you as well as improving our services generally in your area.

Information collected through tracking technologies is used for many purposes including, for example, to:

  • Provide useful features to simplify your experience when you use or return to the Services
  • Deliver relevant content based on your preferences, usage patterns and location
  • Monitor and evaluate the use and operation of the Services
  • Analyze traffic on the Services and on websites or mobile applications of third parties
CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform  technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online  tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals.  Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, account, or other legal or regulatory requirements).  No purpose in this policy will require us keeping your personal information for longer than sixty (60) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How We Safeguard Your Information

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.  However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.  Although we will do our best to protect your personal information, transmission or personal information to and from our services is at your own risk.  You should only access the Services within a secure environment.

Linked Websites

The platform may contain links to third-party websites and platforms of interest, including advertisements and external services, that are not affiliated with us.  Once you have used these links to leave the platform, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information.  Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information.  We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or platforms that may be linked to or from the platform.

Preventing Identity Theft

In order to help us protect your personal information, it is important that you always keep your account information safe. We recommend that you consider the risk of sharing your username, password, or PIN with anyone.

Note that we will never initiate (unless otherwise stated for a specific product or service application), a request via email for your sensitive information (e.g., Social Security number, username, password, PIN or account number). If you receive an email asking for your sensitive information, you should be suspicious of the request and promptly report the suspicious activity.

Please be aware, however, that in certain telephone and in-person transactions we may ask for your full Social Security number, account number or other information to verify your identity before conducting the transactions you have requested. For example, we may ask for such information to verify your identity when you place a call to us. We will never request that you disclose your personal ID, password or PIN under any circumstances.

Additional information regarding identity theft and the steps you can take to help protect yourself from fraud can be found on the Federal Trade Commission website.

Do We Collect Information From Minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information.  By using the Services, you represent that you are at least 18.  If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data we may have collected from children under age 18, please contact us at info@nxtmoves.io.

What Are Your Privacy Rights?

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent.  Sensitive personal information may be used, or disclosed to a services provider or contractor, for additional, specified purposes.  You may have the right to limit the use or disclosure of your sensitive personal information.  

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and 
  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for sixty (60) months after account closure.

Your Rights

You have rights under certain US state data protection laws.  However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.  These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)
  • Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
  • Right to opt out of the collecting of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us at info@nxtmoves.io, or by referring to the contact details at the bottom of this document.  

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf.  We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. 

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system.  We will only use personal information provided in your request to verify your identity or authority to make the request.  However, if we cannot verify your identity from the information already maintained by use, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.  

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.


Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@nxtmoves.io.  We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.  If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS POLICY?

Do We Make Updates To This Policy?

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  The updated version will be indicated by an updated “Last Updated” date at the top of this Privacy Policy.  If we make material changes to the Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.  You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the platform  after the date such revised Privacy Policy is posted.

How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may contact us by post at:

NXTMOVES, Inc.

2827 Peachtree Road, Suite 417

Atlanta, GA  30305

How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.  You may also have the right to withdraw your consent to our processing of your personal information.  These rights may be limited in some circumstances by applicable law.  To request to review, update, or delete your personal information, please email us at info@nxtmoves.io.