Information We Collect
When you access our Interfaces and access, receive and use our Products and Services, we may collect the following information:
(a) Contact Information. Information you provide to us, such as name and email address;
(b) Transaction Information. A record of your transactions using our Services such as timestamp, type and quantity of your transactions and the underlying cryptocurrency;
(c) Financial Information. Your Ethereum network address, cryptocurrency wallet information, transaction history and fees paid;
(d) Online Information. Your geolocation, IP Address and operating system browser fingerprint;
(e) Communications Information. Information regarding your communications and other interactions with us;
(f) Usage and Diagnostics. Information regarding your usage of our Services, such as user preferences, conversion events, and data collected via cookies and other technologies;
(g) Information From Third Parties. Information about you from other sources as required or permitted by applicable law. We may use this information in conjunction with other information (such as information we obtain from the Interfaces) to comply with applicable laws and limit the use of our Services in connection with fraudulent, improper or illegal activities;
(i) Correspondence and Content. Within any messages you send to us (such as feedback and questions to our support team), we may collect your name and contact information, as well as any other content included in the message. You may also choose to voluntarily provide other information to us that we have not solicited from you, and, in such instances, you are solely responsible for such information;
(j) Wallet Address. We may collect the wallet address you use to connect to the Interfaces to block wallets that are associated with certain legally prohibited conduct from Interface. Separately, we may collect your wallet address as part of "Usage Information" (as described below) to improve the Interface and user experience of the Services;
(k) Usage Information. We may collect information about how you use the Interfaces and Services, including your wallet address, the time you access the Interfaces, pages you visit, the features and assets you interact with, the links you click, and the search queries you make. By analyzing this data, we gain a deeper understanding of user behavior, which in turn allows us to make continuous improvements to the Interfaces and enhance the overall user experience; and
(l) Device Information. We may collect information about the device you use to access the Interface, such as the device type, operating system, browser type, and screen height and width. This information helps us optimize the Interface for different devices and troubleshoot any technical issues.
We may use collected information to:
(a) Provide Services. Provide, maintain, monitor and improve our Services, including to process transactions; open and maintain user accounts; and send confirmations, notices, updates, alerts and other support messages;
(b) Customer Support. Provide, monitor and improve customer support, such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support, administrative messages; detecting, preventing, and addressing fraud, breach of our Terms of Service, and threats, or harm; and compliance with legal and regulatory requirements;
(c) Safety and Security. Help protect the safety, security and integrity of our Services, including by monitoring for fraudulent, unauthorized or illegal activities; complying with legal requirements; monitoring and verifying identity or service access; fighting spam, malware or security threats; and enforcing our agreements with third parties and enforcing our Terms of Service;
(d) Troubleshooting. Detect, prevent and address technical issues;
(e) Consent. Purposes for which we have obtained your consent, as required by applicable laws;
(f) Legal and Compliance. Investigate or engage in legal and compliance related functions, including by comparing your information with information obtained from other sources, addressing and resolving claims and disputes, or as requested by regulators and government entities; or
(g) Other Permitted Uses. As described below under the “Information Sharing and Disclosure” heading or in any other way we may describe when you provide the information or with your consent.
Information Sharing and Disclosure
We may disclose collected information:
(a) Provide Services. To provide Services, including to help service transactions and provide customer service and support;
(b) Affiliates and Service Providers. To third party service providers and affiliates that support our activities or technology platform. Examples include hosting our web servers, analyzing data, providing marketing assistance, further development of our Interfaces and Services and providing customer service;
(c) Our Protection and the Protection of Others. To legal or regulatory authorities if required by them or we deem it appropriate, or if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to:
- Conform to legal requirements or comply with legal processes (including subpoenas);
- Enforce or apply our terms of service and other agreements;
- Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
- Stop any activity that we consider illegal, unethical, or legally actionable;
(d) Aggregated or Anonymized Information. On an aggregated or anonymized basis with our partners, other site visitors and other third parties, including so that they can understand our volume and usage of our Services. Such information will not be considered your information because it will be anonymized and aggregated in such a way that it cannot reasonably linked back to a specific user;
(e) With Your Consent. For any other purpose or to third parties if you consent to such disclosure; and
(f) Business Transactions. In the event of a reorganization, financing, investment, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any of our business, assets or stock, or bankruptcy or similar proceedings.
Transfer of Information
Collected information may be transferred to and maintained on computers located outside of your jurisdiction of residence where the data protection laws may differ from those of your home jurisdiction. Regulators or government entities in that jurisdiction may be able to obtain access to your information through the laws of the jurisdiction. When we engage a third-party service provider, we include customary confidentiality and non-disclosure obligations from that service provider regarding any collected information that is provided to it.
Retention of Information
Our Policy Toward Children
No persons under 18 are eligible to utilize our Services and we do not knowingly collect information from anyone under the age of 18. In the event that we become aware that we have collected information from children without verification of parental consent, we take steps to remove that information from our servers.
Security of Data
The security of user information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its security.
Links to Other Sites
Additional Matters Relating to Residents of the European Economic Area
The GDPR in the European Economic Area and in the United Kingdom distinguish between organizations that process personal data for their own processes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Services.
Processing of Your Personal Data
We rely on different legal bases to process your Personal Data (as set out in the “Information We Collect” section) depending on the specific purposes for which we process your Personal Data.
(a) Providing you with requested Services. When you connect your wallet and use our Services, we process your online information, transaction information and financial information, as well as other Personal Data you choose to provide, if any, to deliver your requested Services. To the extent this requires processing your Personal Data, we rely on the performance of your requested Services.
(b) Responding to queries and for customer support purposes. If you contact us, we may collect the information you provide to us (such as contact information and process the content of your communication and related details, such as time and date of the communication and with whom you corresponded). In this case, we use your Personal Data to provide relevant customer service, respond to inquiries and fulfill requests. To the extent your communication requires the processing of your Personal Data, we rely on the performance of your requested functions to process your Personal Data.
(c) Enabling your use of our Interfaces. When you use our Interfaces, we may collect technical information associated with the device you use, including technical identifiers that identify the device or location, such as IP address. Depending on your cookie settings, we may also collect information concerning your browsing behavior and engagement information. We process your Personal Data collected through our Interfaces to enable access to our Interfaces and to correctly deliver content and functionalities. This processing is based on our legitimate interests.
Recipients of Your Personal Data and Data Transfers
We only share Personal Data with others if it is legally required or if there is another legal basis for doing so.
Your Personal Data is processed by third-party processors that operate on our behalf. For example, we rely on processors to safely store your Personal Data and to send you our newsletters. We carefully select our processors and contractually require them to maintain the safety and integrity of your Personal Data. Our processors are only authorized to process your Personal Data according to our explicit instructions.
Moreover, we collaborate with others that assist us in delivering and improving our Services to you and to comply with potentially applicable laws and regulations.
In order to process your Personal Data for the purposes outlined above, we may transfer your Personal Data to services located outside of the European Economic Area, such as any country where we have partners or service providers.
- A contractual arrangement being in place between us and the third-country recipient that is based on the standard contractual clauses for international data transfers adopted by the European Commission; or
- Any other transfer mechanism or transfer tool that legitimizes the international transfer of your Personal Data in compliance with applicable data protection law.
Where we rely on appropriate safeguards for the transfer of your Personal Data, we will assess whether these safeguards can sufficiently protect your personal data so that the level of protection guaranteed in the European Union is not undermined by the transfer. If this is not the case, we will take the additional measures necessary to provide appropriate protection for your Personal Data. If it is not possible to provide for appropriate protection of your Personal Data, we will not transfer your personal data to the recipient in a third country, or will transfer your Personal Data only if and to the extent that another mechanism justifies the transfer of your Personal Data in accordance with applicable data protection law. To obtain a copy of these data protection safeguards or to obtain information about their applicability, please send a request via email to email@example.com.
Your Rights as a Data Subject
If you are a user in the European Economic Area or the United Kingdom, you maintain certain rights under the GDPR, and include the following:
- You have the right to request access to your Personal Data that we process.
- You have the right to obtain the rectification of any inaccurate Personal Data about you. Your rectification request must be supported by evidence of the inaccuracies in the data you are seeking to have corrected.
- Where we process your Personal Data based on your consent, you have the right to withdraw such consent at any time.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the erasure of your Personal Data.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the restriction of processing of your Personal Data.
- Where we process your Personal Data based on our legitimate interests, you have the right to object to the processing of your Personal Data on grounds relating to your particular situation. However, you can always object to processing for direct marketing at any time without any charge or justification.
- If we process your Personal Data with your consent or to fulfill a contract and the processing is carried out by automated means, you have the right to receive the Personal Data you provided to us in a structured, commonly used, and machine-readable format and to transfer this information to another controller.
- We do not use automated decision-making processes that have a legal or similarly significant effect on you.
To exercise any of the rights mentioned above, you can send a request via email to firstname.lastname@example.org. Please state clearly which right you wish to exercise and provide reasons or proof to support your request if required. We will acknowledge receipt of your request and proceed to review it. If your request is valid, we will honor it as soon as possible. In case we have doubts about your identity, we may request additional information to verify it.
If you are not satisfied with how we handle your Personal Data, please inform us by sending an email to email@example.com. You also have the right to lodge a complaint with a supervisory authority. You have the choice of submitting this complaint to the supervisory authority of the EU member state where you normally reside, where you have your place of work, or where the alleged infringement was committed.
(1) Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the access, receipt and use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy
(2) Behavioral Remarketing Cookies
(3) Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy