Last updated: July 20, 2022
Information We Collect
The categories of personal information we collect depend on how you interact with us, our App, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our App, and information from other sources such as third-party services and organizations.
Information you provide to us in order to use our App may include:
- Identity information, such as your first name, last name, username or similar identifier, title, date of birth and gender;
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username and password, interests, preferences, feedback and survey responses;
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our App, receive customer support or otherwise correspond with us;
- Transaction information, such details about transfers you make on our App;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
- Digital Asset Wallet Address; and
- Other information necessary for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance purposes
As you use our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including but not limited to, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps. See “Log Data” and “Device Data” below for details.
When you use our App, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the App, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
When you use our App or interact with our services, we may automatically collect data about your device, such as:
- Device Type
- Operating System
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Wallet Address Information
When you create a wallet on our App, encrypted wallet public key and private key pairs are automatically generated by the App and stored in your device. We have no control of or custody over your wallet keys.
Collection and Use of Information
We may collect information from you when you do any of the following on our App:
- Register for an account
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to provide you with our platform’s core features and services
- to enable you to customize or personalize your experience of our App
- to contact and communicate with you
- to enable you to access and use our App, associated applications, and associated social media platforms
- to comply with our legal obligations and resolve any disputes that we may have
Specifically, with constantly changing regulatory regime over cryptocurrency, we may be required by law to keep record and disclose your personal information on certain transactions via our App. For example, FinCEN in late 2020 proposed new rules to require banks and money service businesses to submit reports, keep records, and verify identity of customers in relation to transactions over a certain value with private wallets. Though we do not consider ourselves a money service business, we may nevertheless be subject to such recordkeeping and reporting requirements or similar rules and regulations in the near future.
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our App to improve our App and your experience on it.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
We do not aim any of our products or services directly at children under the age of 18, and we do not knowingly collect personal information about children under 18.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- a parent, subsidiary, or affiliate of the Company
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our assets and business
- With the designated blockchain, we will share your public wallet address and any transaction details to facilitate any transaction request you submit via the App;
- With vendors, consultants and other service providers who need access to such information to carry out work on our behalf; it is our practice to require such parties to handle the information in a manner consistent with our policies;
- In response to a request for information if we believe disclosure is in accordance with, or as otherwise required by, any applicable law, regulation or legal process;
- If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of us or others;
- In connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business to another company;
- With your consent or at your direction, including if we notify you through our App that the information you provide will be shared in a particular manner and you provide such information.
Your Rights and Controlling Your Personal Information
- Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
- Access: You may request details of the personal information that we hold about you.
- Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
- Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
- Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our App may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.