Effective Date: July 13, 2022
Some of the information we collect about you identifies you. If it identifies you, we call it “Personal Information.” Personal Information does not include any information that is publicly available or information that has been anonymized to the point where a specific individual or household cannot be identified from the remaining information. If we associate non-identifiable information with information that identifies you, we will treat it as Personal Information.
We only collect and use your Personal Information when we have a legitimate reason for doing so. We only collect Personal Information that is reasonably necessary to provide our Services to you and for the purposes set forth in this Policy. The information we collect can come from information you provide, information we collect through automated means, information we collect from other sources, and information we infer.
Information You Provide.
1. Profile Information. When you register on the Site and set up an account (“Account”), we may need to collect some details about you. The Personal Information you provide may include the following:
- Profile information associated with you; and
- Other Personal Information you choose to provide us when you interact with us, including but not limited to social profile information provided by social authentication providers.
You are responsible for the accuracy of the Personal Information that you submit. You can choose whether you provide Personal Information to us, but if you do not provide it to us, we may not be able to offer certain features of the Services.
- 1.Other Information. When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need to resolve your question. Note that our ability to resolve your question could be dependent upon you disclosing the information we require.
1. Usage and Device Information. When you use our Services, we automatically collect certain browser or device-generated information by using various types of technology (“Usage Information”). This information includes, but is not limited to:
- Your IP address or other device addresses or IDs;
- Web browser and/or device type;
- Blockchain address, wallet type, and date/time stamps
- The pages or other content you view or interact with on the Services;
- The server from which you are accessing our Services; and
- The date, time, and place of accessing our Services.
We may also use these technologies to collect information regarding your interaction with email messages, such as whether you have opened, clicked on, or forwarded a message. We also collect your blockchain address which may be associated with Personal Information when you use our Services.
2. Geographic Information. Our Services may collect information about the exact location of your device using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. You generally can disable the collection of this information in your Device settings. Some of our Services may not work properly without information about your location.
4. Analytics. We may work with different companies that offer services that can assist us in better understanding how users interact with and use the Services. For example, we may use a product called Mixpanel by permitting Mixpanel to use technologies such as web beacons and cookies to collect certain non-personally identifiable information that helps us understand your use of our Services. We may permit Mixpanel and other third-party analytics providers to combine information collected through our Services with information collected from third-party services, and these analytics providers may use this information to help us better understand our users. These analytics providers may also use this information to help their other customers better understand their users.
C. Information from third parties. We may, from time to time, supplement the information we have about you with information from third parties for various purposes, including to enhance our ability to serve you.
1. Wallet Providers. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallet providers. We may add this to the data we have already collected from or about you through our Services.
2. Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.
We may use any information about you, including your Personal Information, to develop inferences about you. This includes customer profiles, usage preferences, or other information about your anticipated or assumed actions or behaviors.
To Provide Services.
We use your information to improve your experience and to deliver the Services you have requested. We will use your information to customize or personalize your experience with our App and to provide you with customer support. We may also use your information if we need to contact you about your relationship with us.
We use your information to help you explore and create Non-Fungible Tokens (“NFTs”) using our tools and, at your own discretion connect directly with others to purchase, sell, or transfer NFTs on a public blockchain.
To Manage Our Business.
We also use the information for our business purposes, which include the following:
- Planning and managing our activities, including marketing our Services, researching and analyzing your use of the Services or your visits to the Site, tracking user behavior, and collecting feedback;
- Developing inferences about you;
- Administering our Services, such as managing agreements with our suppliers;
- Monitoring aggregate usage metrics such as total number of visitors;
- Developing new features, functionalities, and services;
- Operating, evaluating, maintaining, improving, or developing our Services and Site operation;
- Protecting and ensuring the safety of the Services, our confidential and proprietary information, and our employees;
- Managing, protecting against, and investigating fraud, risk exposure, claims and other liabilities, including but not limited to violation of the Terms, laws or regulations;
- For internal recordkeeping purposes;
- Anonymizing your Personal Information for further internal and external uses in a manner that does not identify you; and
To Make Inferences.
We may use any of the information we collect about you to develop inferences about you, including your interests and characteristics about you.
To Provide Services.
We may share Personal Information as necessary to provide our Services, complete a transaction, market the Services to you, or fulfill your requests. For example, we work with third party service providers to help us provide the Services and we may need to share your information with them so they can fulfill their obligations to us. We may share your information to monitor, improve, or better market our Services such as with third party cookie providers.
To Manage Our Business.
1. Related Parties and Affiliates. We may share Personal Information with a parent, subsidiary, or affiliate of our company.
2. Service Providers and Professional Advisors. We work with third party service providers to help us provide the Services and to assist us in operating our business. For example, service providers are used in areas such as email management and deployment, analytics, marketing, advertising, market research, identity validation, content distribution, customer service, payment fulfillment, logistics, website maintenance and data storage and security, and we share your Personal Information so they can fulfill their obligations to us. We may also share your Personal Information with our professional advisors such as our legal representatives or insurance brokers.
3. Legal Requirements and Law Enforcement. We will disclose your Personal Information if we have a good faith belief that such disclosure is necessary to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements. We will also disclose your Personal Information to respond to a physical threat to you or others or to defend or assert legal rights of us or others. We may disclose your Personal Information to credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you.
4. Dispute Resolution. We will disclose your Personal Information as necessary to resolve disputes, inquiries or complaints. We may disclose your Personal Information if we believe you have violated our Terms.
5. Business Transfers. We may also share your information in the event we are transferred or sold to another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
6. Other Sharing of Personal Information. We reserve the right to disclose Personal Information that we believe, in good faith, is appropriate or necessary to: (a) take precautions against liability, (b) protect us or others from fraudulent, abusive, or unlawful uses or activity, (c) investigate and defend us against any third-party claims or allegations, (d) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (e) protect our property or other legal rights, or the rights, property, or safety of others.
For Third-Party Purposes.
2. No Sale of Personal Information for Marketing. We do not sell, rent or lease any Personal Information to any third party for commercial or marketing purposes without your consent.
Aggregate and Anonymous Information. We may make automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third-parties for various purposes, including: (a) for compliance with various reporting obligations; (b) for business or marketing purposes; (c) to assist us in improving the products or Services; or (d) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain content, services, advertisements, promotions, and/or functionality available through the Services.
You are responsible for securing and maintaining the privacy of your login information and password(s) and verifying that your Personal Information is accurate and current. We are not responsible for the privacy or security of any information on the Services that you make publicly available or what others do with information you share with them. Please think carefully before deciding what information you share, including Personal Information, in connection with your use of the Services.
Be aware that certain Personal Information and other information in connection with your use of the Services may be stored on your device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.
You may, of course, decline to share certain Personal Information with us in which case, we may not be able to provide some of the features and functionality of the Services.
A. Marketing Purposes and Commercial Email Opt-Out. When you create an Account with us that requests your email address, unless you opt-out, we will use your email address to deliver digital communications from us. When you communicate with us through any means such as chat or email, we may use your contact details for marketing communications. When you sign up to receive digital communications for any of our Services, you can choose to opt-out of receiving additional digital communications from us or our advertisers or sponsors. You can unsubscribe from email and other digital communications by following the instructions in the communication or by sending a request to us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site.
If you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.
We do not share Personal Information with third parties for their own direct marketing purposes unless you give us permission to do so.
B. Applicable Law. Subject to applicable law, you may have different rights regarding our use of your information. For example, you may have the following rights:
- Right to request access to and to check what Personal Information we maintain about you;
- Right to request copies of your Personal Information;
- Right to update and correct inaccuracies in your Personal Information;
- Right to have your Personal Information deleted;
- Right to request restriction of the collection, processing, or use of information about you;
- Right to request data portability;
- Right to lodge a complaint with a supervisory authority; and
- In some cases, the right to object to our processing of your information and to withdraw your consent to our processing of your information.
You can perform many of these actions by going back to the specific Service, logging-in, and making the desired change.
When you request the deletion of your information, object or withdraw your consent to the processing of your information, we may not be able to provide all the features of the Services to you. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the Services from our servers.
To exercise any of these rights please contact us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site. We will promptly review all such requests in accordance with applicable laws.
Please see the Special Notice for California Consumers and Special Notice for International Users for more information about rights that apply to residents of certain geographic locations.
“Cookies” are alphanumeric identifiers that are stored on a computer, browser, laptop, tablet, mobile phone, or other device (each, a “Device”), which collect information about your activity, browser, and Device. A “web beacon” (sometimes referred to as pixels and tags) is a small object or image that is embedded into a web page, application, or email, and is used to track activity.
We may use both session (for the duration of your visit) and persistent (for the duration of a fixed period of time) cookies and tracking technologies. A cookie does not provide us with access to your computer or to Personal Information beyond what you provide to us. We do not store Personal Information in cookies.
Some cookies are necessary to use the Services, and these cannot be disabled. Other cookies are not required to use our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings.
We follow generally accepted industry standards, including the use of appropriate administrative, physical, and technical safeguards, to protect the Personal Information submitted to us. For example, when you enter Personal Information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.
Despite efforts to protect your Personal Information, no method of electronic transmission or storage is 100% secure, and there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the internet may be intercepted.
If we learn of a security system breach, then we may attempt to notify you so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing, and we will follow all applicable laws.
We will retain your Personal Information as long as your Account is active or as needed to provide you Services. At any time, you can remove your Personal Information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. See “Your Choices and Rights” below for more information on how you can remove your Personal Information.
Even though you may make changes or request deletion of your Personal Information, we may retain all information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
- Commercial information
- Transaction information
- Electronic network information and online identifiers (e.g., IP address)
- Email address, postal address, telephone number
- Geolocation data
C. Disclosures of Personal Information. As is common practice, within the past 12 months, we have disclosed Personal Information in all or substantially all of the categories identified in Section A of this Additional Notice for California Consumers to vendors who provide services to us, in connection with a sale or transfer of all or part of our business, and as otherwise provided in Section 3 (“How We Share Your Information”).
D. Right to Opt Out of Sale of Personal Information. Although we do not sell Personal Information, you have the right to opt out of the sale of your Personal Information. To the extent we sell Personal Information in the future, you will have the right to request us to stop “selling” your information by using a “Do Not Sell” button on our home page.
E. Your California Privacy Rights. If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
1. Right to Access and Right to Know Your Personal Information. You have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
- the categories of Personal Information we have collected about you;
- the categories of sources from which the Personal Information is collected;
- our business or commercial purpose for collecting or selling Personal Information;
- the categories of third parties with whom we share Personal Information;
- the specific pieces of information we have collected about you; and
- the categories of Personal Information about you that we disclosed for a business purpose.
2. Right to Deletion of Personal Information. You have the right to request that we delete Personal Information about you that we have collected from you.
3. Right to Non-Discrimination. We may not discriminate against you because of your exercise of any of the foregoing privacy rights, or any other rights under the California Consumer Privacy Act, including by:
- Denying you goods or services;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.
5. Agent Authorization. You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us to make a request on your behalf. Even if you choose to use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.
F. Do Not Track. Please note that our Services are not designed to respond to “do not track” requests from Web browsers.
G. Shine the Light. California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing. We may share Personal Information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us for more information using either of the addresses provided in the Contact Us section. In your message, please include a description or your request, as well as your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email, online form or postal addresses.
If you do not consent to such transfer, you may not use the Services. If you choose to access and use the Services from outside the United States, you acknowledge that you are doing so on your own initiative, at your own risk, and are responsible for compliance with applicable laws.
B. Additional Disclosures for European Data Subjects. If we are subject to the General Data Protection Regulation (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”), the legal bases for the processing of your Personal Information are:
- Processing is necessary for us to perform a contract with you;
- Our prevailing legitimate interest to provide the Services, improve your overall customer experience and achieve the purposes set out above or in our Terms; and
- Processing is necessary for us to comply with legal obligations.
Certain users may be considered “data subjects” for whom the processing of Personal Information is subject to the GDPR or the UK GDPR (each, a “Covered Person”).
Covered Persons have the rights described in sections (1) through (4) below:
- 1.Right of access, rectification, erasure, and restriction of processing: You may obtain access to your Personal Information stored by us. If we process or use your Personal Information, we shall endeavor to ensure, by implementing suitable measures, that your Personal Information is accurate and up to date for the purposes for which it was collected. If your Personal Information is inaccurate or incomplete, you may obtain the rectification of such Personal Information. You may obtain the erasure or restriction of processing of your Personal Information in situations where no legitimate business purpose exists, or the further storage is unnecessary.
- 2.Right to data portability: You may receive the Personal Information that you have provided to us, in a structured, commonly-used, and machine-readable format or transmit this information to another controller.
- 3.Right to object: You may object, on grounds relating to your particular situation, to the processing of your Personal Information. To the extent your Personal Information is processed for reasons other than direct marketing, you understand and agree that we have compelling legitimate reasons for information processing, such as providing access to our Services. You may use ad-blocking software to limit information capture and usage. Making a request does not guarantee that the request will be honored.
- 4.Right to withdraw consent: If you consented to the collection or processing of your Personal Information, you may withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal.