LAST UPDATED: Jan, 2023
1. Collection of Information
(a) Information You Provide to Us
We collect information you provide directly to us. This may include, but is not limited to:
(i) contact information, such as email address;
(ii) your digital wallet address;
(iii) feedback and correspondence, such as comments and “likes” you provide to Content (a defined in the Terms of Service), information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us;
(iv) Content you provide to the Services;
(v) usage information, such as information about how you use the Services and interact with your user account, digital wallet, blockchain protocols and services and us; and
(vi) marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.
(b) Automatically Collected Information
When you access or use the Sites or our Services, we automatically collect information about you, which may include, but is not limited to:
(i) Log Information: We may collect log information about your use of the Sites and the Services, including without limitation the type of browser you use, access times, pages viewed, products and/or services purchased, your IP address and the page you visited before navigating to the Sites or our Services.
(ii) Device Information: We may collect information about the computer or mobile device you use to access the Sites and our Services, including the hardware model, operating system and version,unique device identifiers, and mobile network information.
(iii) Information Collected by Cookies and Other Tracking Technologies: We may use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites, our Services and your experience, see which areas and features of the Sites and our Services are popular and count visits. Web beacons are electronic images that may be used in the Sites and our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below.
(iv) We may also use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://policies.google.com/privacy?hl=en
(c) Information We Collect from Other Sources
We may obtain information from other sources, including third parties and public blockchain data and information, and combine that with information we collect through the Sites and our Services.
(d) Information We Will Never Collect
We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
2. Use of Information
We use the information we collect to enable you to access and use and otherwise provide, maintain, and improve the Sites and our Services. We may also use the information we collect to:
(i) send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
(ii) communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you, which maybe provided by any means, including by e-mail, in-app notifications, push notifications and display advertising;
(iii) personalize your experience when you visit or use the Sites or our Services;
(iv) administer contests, promotions, surveys and other Service features;
(v) monitor and analyze trends, usage and activities in connection with the Sites and our Services;
(vi) comply with applicable laws, lawful requests and legal processes, including responding to court orders or requests from regulatory authorities;
(vii) generate aggregate or de-identified data and use such data (including without limitation digital wallet and other blockchain transaction data) for any purpose, including research and analytics; and
(viii) detect, investigate and prevent fraudulent transactions and other illegal activities, enforce our agreements with users (including our Terms of Service) and protect our rights and property and of others.
3. Sharing of Information
(i) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including hosting, email and database services and in connection with providing Content through our Services;
(ii) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
(iii) if we believe your actions are inconsistent with our user agreements or policies(including our Terms of Service), or to protect our rights, property and our safety or that of others;
(iv) in connection with, or during negotiations of, any proposed or actual merger, sale of company assets, financing, securitization, insuring, acquisition of all or a portion of our business by another company, or bankruptcy transaction or proceeding;
(v) between and among us and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
(vi) With your consent or at your direction.
4. Advertising and Analytics Services Provided by Others
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
6. Data Retention
We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. There is no single retention period applicable to the various types of personal information collected. Please contact us if you would like to delete any personal information we hold about you. We also reserve the right to continue to hold personal information about you to the extent it is required to be held by us by law, rule or regulation.
7. Disclaimer About Sharing Personal Information Online
You acknowledge that when sharing personal information online, there is always a risk of data breaches, including data breaches in which third parties unlawfully access our systems or the systems of our third-party providers, which store personal information.
8. Limitation on Liability
9. Transfer of Information to Other Countries
We are based in Canada. However, we may transfer personal information to outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as customer service and support, marketing and analytics, data hosting or processing services or similar services. Some of these service providers may be located outside of Canada, including the United States, and as a result your personal information may be processed in the United States or elsewhere outside of Canada, where local laws may permit foreign government and national security authorities to access personal information in certain circumstances.
10. Residents of the European Economic Area
(a) Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
(i) with your consent;
(ii) to provide access to or perform the Services you have requested from us or, upon your request, to take the steps necessary to provide you with the Services; or
(iii) in the furtherance of our legitimate interests in maintaining business relationships and communicating with you as a business contact, about our activities and Services and providing, securing and improving the Services.
You have consented to the processing of your personal data for one or more specific purposes. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you want to, please contact us at the contact details indicated below.
(b) Data Subject Requests
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below. Please note that the limitation or deletion of your personal data may mean we will be unable to provide you with the Services. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing.
(c) Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, pleasesee: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
11. Residents of California
California Civil Code Section § 1798.83permits users who are California residents to request certain information, including the categories of personal information disclosed to third parties for their marketing purposes and the names and addresses of those third parties, regarding our disclosure of personal information to third parties for their direct marketing purposes, if any. If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please contact us as indicated in the “Contact Us” section below.
12. Your Choices
(a) Account Information
You may update, correct or delete information about you at any time by contacting us as indicated in the “Contact Us” section below. Please note that we may retain cached or archived copies of information about you for a certain period of time. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites and our Services.
(c) Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions in those communications or by contacting us as indicated in the “Contact Us” section below. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
(d) Google Analytics
If you are under the age of majority in your jurisdiction of residence, you may use the Sites or the Services only with the consent of or under the supervision of your parent or legal guardian. If we learn that we have received any information directly from a child under the age of majority without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian)to inform the child that he or she cannot use the Site or the Services and subsequently we will delete that information.
15. Contact Us
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