Privacy Policy

BuySellHODL Privacy Policy


As of January 29, 2019



This Privacy Policy (the “Privacy Policy”) is applicable to your use of the BuySellHODL Platform operated by Lerner Ventures Inc. (“Sponsor” or “we“, “us“, or “our“). The “BuySellHODL Platform” consists of any platform (including without limitation any web, mobile, tablet, pad and/or cloud-based platform, as well as future technologies), along with any server(s) (real or virtual), website(s), webpage(s), domain(s), supporting file(s), hardware, software and/or other content, that are owned, operated and/or controlled by Sponsor, through which Sponsor provides each “Guest” (an individual who is eligible to participate in some activities on the BuySellHODL Platform) and each “Member” (an individual who is eligible to participate in the activities on the BuySellHODL Platform and who has properly completed the registration process) with access to our tournaments, games, contests, sweepstakes and other promotions. The term “User” refers to a Guest or a Member.  This Privacy Policy solely governs information that is collected through your use of the BuySellHODL Platform and does not apply to any personal information collected offline.

By using the BuySellHODL Platform, you agree to be bound by the Privacy Policy, our Terms of Service (the “Terms of Service“), and our Official Rules (the “Official Rules”).  Links to each are available on the BuySellHODL Platform.  All of the terms and conditions contained in the Terms of Service and the Official Rules are deemed incorporated into this Privacy Policy by this reference. In case of a conflict between the Terms of Service, Privacy Policy, and/or the Official Rules, the Terms of Service shall govern.

We are committed to respecting the privacy rights of all Users of the BuySellHODL Platform.  This Privacy Policy is intended to provide you with notice of our information practices, including the types of information gathered and how the information is used and safeguarded.

We may change this Privacy Policy from time to time.  The most recent version of the Privacy Policy will always be posted on the BuySellHODL Platform, with the “As of” date posted at the top of the Privacy Policy.  If we make any material changes to our Privacy Policy or how we handle your information, you will know because the “As of” date of the Privacy Policy will change.  If we are going to use any information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change.  If you do not consent, your information will be used as agreed to under the terms of the Privacy Policy in effect at the time we obtained that information. By accessing the BuySellHODL Platform after the “As of” date, you are deemed to consent to our then-current Privacy Policy.

Your use of the BuySellHODL Platform and any personal information you provide on the BuySellHODL Platform remains subject to the terms of this Privacy Policy, the Terms of Service and Official Rules.  If you do not agree with any term in this Privacy Policy, do not use the BuySellHODL Platform.


The BuySellHODL Platform is not aimed at nor intended for individuals who are less than the age of majority in their country, state, province, or jurisdiction of residence.  If you are under the age of 18 (or less than the age of majority in your country, state, province or jurisdiction of residence), please do not use the BuySellHODL Platform. We do not knowingly accept registration information from anyone under the age of 18.  Additionally, the BuySellHODL Platform supports and complies with the United States’ Children’s Online Privacy Protection Act (“COPPA”) and other laws.  Every Member hereby agrees that all information you provide, including but not limited to date of birth, shall be truthful and correct.


Information We Collect

Registration Information

Registration information (“Registration Information“) is information that identifies you or could reasonably be used to identify you personally (such as your real name, address, telephone number, or e-mail address). In order to access all content available on the BuySellHODL Platform and win prizes, you will be required to register as a Member and create an account through the BuySellHODL Platform.  To create a Member account, you will be required to provide certain Registration Information (e.g., your full real name, e-mail address, telephone number and date of birth).  All information provided at the time of registration must be truthful and accurate.  We may also request certain additional personal information in order to participate in certain other activities available through the BuySellHODL Platform including, but not limited to, participating in surveys or in order to receive a prize.  In some cases, if you choose not to provide us with the additional personal information, you will not be able to access all areas of the BuySellHODL Platform and we will not be able to award any prize you may win. If you do not want your Registration Information collected, please do not submit it to us. Additionally, we may collect credit card, debit card, prepaid card, gift card or other information provided by you for billing and payment purposes. We may offer you the opportunity to submit other information about yourself (such as gender, occupation, hobbies, interests, location, etc.) or you may provide information through the BuySellHODL Platform or within “User Content” (as such term is defined in the applicable Terms of Use). Such information shall also be covered by this Privacy Policy. Any actions you perform or information you provide that can be seen by other users of the BuySellHODL Platform, is considered public and should be provided at your own risk and discretion.  Finally, we may also collect information about your mobile provider, your mobile device and your usage of any mobile apps you download in connection with the BuySellHODL Platform.


By registering on the BuySellHODL Platform and agreeing to the BuySellHODL Terms of Service and Official Rules, you enter into a contract with us, and we process your Registration Information and other personal information you may provide to us to perform our obligations under the contract (for example, contacting you to tell you that you have won a prize).  You can cancel the contract you enter into and withdraw from the BuySellHODL Platform , but we may continue to process your Registration Information in certain instances after you withdraw, in accordance with this Privacy Policy, the Terms of Service and Official Rules and applicable laws. When we process your Registration Information based on our legitimate interests, we put in place appropriate safeguards and perform appropriate analysis to ensure that our legitimate interests do not override your interests or fundamental rights or freedoms.


We will use your information to fulfill your specific requests, confirm your eligibility to receive a prize/offer and to send you account-related information. In addition, the personal information you provide will allow us to send you messages, with your prior consent, about things including new products, features, enhancements, special offers, and events of interest.  As required by applicable law, you may, at your discretion, opt-out from these types of communications at any time by following the instructions in any such communications you receive. Additionally, we may use third party services to help us operate our business and the BuySellHODL Platform or administer activities on our behalf. We may share your information with these third parties for those limited purposes.

You may decide to provide us with another person’s email address so that person may be invited to join the BuySellHODL Platform or so that we may facilitate your communication with other people through the BuySellHODL Platform (such as when you upload an address book).

You may also provide us with another person’s contact information for purposes of delivering information through a “SNS” (as defined below). We use this information to contact and, if applicable, remind that person that he or she has been invited to join the BuySellHODL Platform or has received content through a SNS. All invitees are provided with the option not to receive further invitations from us. We may disclose such information if required to do so in order to comply with legal process, as set forth above.

Your Registration Information will primarily be hosted in the United States.  However, you understand and agree that the BuySellHODL Platform may be hosted, maintained and accessed globally, including outside your country of legal residence and including in countries that may, in certain instances, be less protective of your personal information than the jurisdiction in which you reside.


Registration Information will be retained for the duration of your relationship with us, the length of time required by applicable legislation, or otherwise a reasonable period of time and we or our third party data processors will amend or dispose of your Registration Information when no longer necessary.


Information Shared With Facebook and other Social Networking Services.

You may be given the option to use the BuySellHODL Platform through a social networking site (“SNS”) such as Facebook.  By clicking allow on the Facebook permission authorization we will automatically import information from your Facebook profile, including without limitation, your Facebook user ID, profile picture, Facebook profile name, email address, date of birth, first name, last name, gender, and Facebook friends (“Imported Facebook Information”).  When linking your account the authentication of your login credentials is conducted through the applicable SNS.  You should make sure that you are comfortable with the information your SNS may make available to us by visiting the SNS’ privacy policy and/or modifying your privacy settings directly with the applicable SNS.  By authorizing the SNS to provide this information to us we reserve the right to use, transfer, assign, sell, share and provide access to such information in the same ways described in this Privacy Policy.

User Content.

Some features of the BuySellHODL Platform may allow you to provide content to the BuySellHODL Platform. All content submitted by you to the BuySellHODL Platform may be retained by us indefinitely, even after you terminate your Member account. We may continue to disclose such content to third parties in a manner that does not reveal Registration Information, as described in this Privacy Policy.

Location Information.

The BuySellHODL Platform may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”).  To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services. Additionally, we may also collect and/or receive location information from your use of the BuySellHODL Platform generally, which can come from a variety of sources, depending on how you use or access the BuySellHODL Platform. For example, an image taken from your mobile device may contain location information related to where the image was taken, or a mobile device may report its GPS location at the time Location-Based Services are used.

Information Collected Using Cookies and Other Technologies

In addition to information that you choose to provide to us or allow us to capture through SNSs, we and our third-party service providers may use a variety of online tracking technologies, including cookies, flash cookies, web beacons/GIFs, embedded scripts, or e-tags, that automatically (or passively) collect certain information whenever you visit or interact with the BuySellHODL Platform (“Usage Information”).  Usage Information may include the browser that you are using, the URL that referred you to the BuySellHODL Platform, your IP address, or other unique identifier which is a number that is automatically assigned to the device (“Device”) used to access the BuySellHODL Platform (“Device Identifier”), the regional location derived from your IP address or geo-location data obtained from your Device as permitted in your settings on your Device, all of the areas within the BuySellHODL Platform that you visit, and the time of day, and when and how you interact with the BuySellHODL Platform, among other information.  Usage Information may be non-identifying or may be associated with personal information about you. This Usage Information is used for many purposes including, for example, to provide identifying features to simplify your experience when you return to the BuySellHODL Platform and to maintain your scores when participating in activities on the BuySellHODL Platform.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off such cookies through your browser settings.  Each browser is a little different, so look at your browser “Help” menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies.  To learn how to manage privacy and storage settings for Flash cookies, please click  If you choose to disable cookies on your Device, some features of the BuySellHODL Platform may not function properly.

Non-Personally Identifiable Information

We collect certain non-personally identifiable information in connection with the BuySellHODL Platform.  For example, we may collect click stream data, data on how users navigate the BuySellHODL Platform, and anonymous demographic information..  We use this information in the aggregate to gauge the effectiveness, usage, and popularity of the BuySellHODL Platform, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track Member movement in the aggregate, and gather broad demographic information and track traffic and sales by our affiliates.  We may also use individual information we collect through web logs to send you targeted offers and other communications. We also track which elements of the BuySellHODL Platform are accessed and how long those elements are accessed.

Ad Serving Technology

Third-party vendors may present or serve advertisements to you via the BuySellHODL Platform, provide us with data collection, reporting, ad response measurement, and site analytics, and assist with delivery of relevant marketing messages and advertisements.  These third parties may view, edit, or set their own cookies. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. These vendors may also aggregate Members’ personal information for use in targeted advertising, marketing research and other similar purposes on the BuySellHODL Platform and other websites.  These vendors may also place their own cookies on our Members’ hard drives. For more information please visit the Network Advertising Initiative at and/or the Self-Regulatory Program for Online Behavioral Advertising at

Data Protection

BuySellHODL will make commercially reasonable efforts to protect your Registration Information and other information you provide and ensure the security of the BuySellHODL Platform.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. We cannot guarantee that our Members’ information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical or technical safeguards and we cannot assume responsibility or liability for unauthorized access to our servers and systems.

Linked Sites

Links to or from the BuySellHODL Platform (“Linked Sites“) to other websites, services, or applications may exist.  This Privacy Policy applies solely to information collected by the BuySellHODL Platform.  We do not endorse or sponsor other websites (unless specifically disclosed), we are not responsible for the privacy practices or the content of other websites, expressly disclaim any statements or assertions made on such websites, and deny all liability associated with your use of, and the content on, such other websites.  We encourage you to read the privacy policies or statements of the other websites you visit.

Legal Matters

We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account, when legally required to do so, such as in response to a legal subpoena, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of the BuySellHODL Platform, to limit our legal liability and protect our rights or the rights, property or safety of Members of the BuySellHODL Platform or the public.  In those instances, the information is provided only for that purpose. We reserve the right to disclose any and all types of Member information in special cases when we have reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with our rights or property, other website users, or anyone else that could be harmed by such activities.


Sale or Transfer of Business or Assets

In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information of our Members may be one of the assets sold or merged in connection with that transaction.  Information about our Members may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, and support or funding. In such transactions, information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.


California Privacy Rights

If you are a California resident, you may request information about our practices related to disclosing your personal information to certain third parties and/or opt-out of our sharing of your information with unaffiliated third parties for the third parties’ direct marketing purposes.  Please send your request (along with your full name, e-mail address, postal address, and the subject line labeled “Your California Privacy Rights”) by e-mail to contact (at) buysellhodlapp (dot com).


Control of Your Information/Updating Your Information

Your personal information will be controlled by BuySellHODL., whose principal place of business is 228 Park Ave S, Suite #97707,  New York, NY, 10003-1502. If you would like additional information regarding us, please contact us at contact (at) buysellhodlapp (dot com).

You are solely responsible for maintaining and updating your registration information with current and complete information.  You may edit portions of your Registration Information by sending an email to contact (at) buysellhodlapp (dot com) and requesting the changes required.  After receiving any requested changes to your information, we will make reasonable efforts to ensure that all of your personal information stored in our databases is updated, corrected, changed or deleted, as applicable.  When you deactivate your account we will retain logs of all activity on the BuySellHODL Platform associated with your account along with an archival copy of your information, which might be used by us for recordkeeping and internal purposes, including enforcing this Privacy Policy, our Terms of Service, and the Official Rules and for demographic, reporting and research purposes.


If you would like to request deletion of your information subject to applicable law in certain countries, have questions or requests, would like to exercise other applicable rights under data protection law, wish to obtain a full list of third parties to whom your information may be disclosed for the purposes set out in this Privacy Policy, send an email to contact (at) buysellhodlapp (dot com) so that we may assist you with your request.


If you want to withdraw consent to our use or storage of your personal information or wish to opt-out from receiving email or other communications from us, please send an e-mail to contact (at) buysellhodlapp (dot com). Recognize that withdrawing your consent may limit or preclude your use of the BuySellHODL Platform and may not technically be able to be applied to all of your activities on the BuySellHODL Platform (e.g. any personal information contained in any content you may post/share through the BuySellHODL Platform).


Residents of the European Union also have a right to contact the Data Protection Authority in connection with any questions about their privacy rights or to make a complaint about our data practices. Further information about how to contact your local data protection authority is available at .



Any dispute over privacy is subject to this Privacy Policy and our Terms of Service including limitations on damages, resolution of disputes, and application of the laws of the United States.

If you have any questions or concerns regarding this Privacy Policy, send us an e-mail at: contact (at) buysellhodlapp (dot com) or write to us at 228 Park Ave S, Suite #97707,  New York, NY, 10003-1502.



Definitions of Tracking Technologies

Cookies A cookie is a data file placed on a device when it is used to visit the online service.  HTML5 cookies can be programmed through HTML5 local storage. A Flash cookie (or locally shared object) is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you to your device.  Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.  Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. Please be aware that if you disable or remove cookies or HTML5 cookies on your device, some elements of the BuySellHODL Platform may not function properly, and that when you revisit the BuySellHODL Platform your ability to limit cookies is subject to your browser settings and limitations.

Web Beacons Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in the BuySellHODL Platform pages and messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the online service, to monitor how Members navigate the online services, to count how many e-mails we sent that were actually opened, or to count how many particular articles or links were actually viewed.

Embedded Scripts An embedded script is programming code that is designed to collect information about your interactions with the Kizzang® Platform, such as the links you click on.  The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the BuySellHODL Platform, and is deactivated or deleted thereafter.

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