Archblock Global Privacy Policy
Last Updated: May 2, 2024
Welcome to Archblock! We respect and protect the privacy of those who visit our websites (“Visitors”) and Visitors who create an account and access our Services (“Users”) (together, “you” and “your”).
This Privacy Policy explains how Archblock (Holding) AG and its subsidiaries, (collectively, “Archblock”, “Company”, “we”, “us” or “our”) collect, share, use, store, and protect your personal information when you visit or use this and other online services (our, “Services”) offered by the Company, which include the services offered on our websites, including archblock.com, stablecoins.archblock.com, login.archblock.com , and app.archblock.com (each a “Website” and collectively the “Websites”). Contact details are provided below.
This Privacy Policy supplements the applicable Terms of Use of the Company where you have opened your account.
Please read this Privacy Policy carefully to understand our policies and practices, as it provides a general overview of our privacy practices regarding your personal information. You can learn more about certain jurisdiction-specific information in the applicable sections of this Privacy Policy, including information for individuals residing in the European Economic Area (“EEA”), Switzerland, the United Kingdom, and California.
This Privacy Policy does not apply to websites, applications, or services that are not linked to this Privacy Policy or to those operated by third parties.
Archblock Companies, Contact Information and Data Protection Officer(s)
You can check which Archblock entity you are onboarded with when reviewing the applicable Terms of Use of the product or service you’re using, and this entity is considered a controller of your personal information and documentation (collectively, your “Personal Information”).
If you have any questions with regards to this Privacy Policy or the processing of your Personal Information, we advise you to contact us using the contact information below:
Archblock Companies (“Controllers”) | Contact Information |
|---|---|
Archblock (Holding) AG Renaissance Ambition AG TrueCoin LLC Archblock (Cayman) |
We have appointed a Data Protection Officer (“DPO”). You can also contact the DPO in case of any question in relation to this Privacy Policy or any other inquiries with regards to processing of your Personal Information via the email [email protected].
1. INFORMATION WE COLLECT ABOUT YOU
We collect Personal Information including, but not limited to, the following:
A. Information You Provide Us
Information Category | Description |
|---|---|
Basic User Information | Name, Address, Date of birth, Nationality, Country of residence, Citizenship, Gender, Occupation Phone number, Email Address |
Supplemental Identification Information | Utility bills and other forms of evidence (for your billing or proof of address), Photographs and/or videos, Government-issued identity documents, e.g. passport, Employment information (e.g. company name), Proof of address |
Electronic Identification (“EIDV”) Information | Biometric information generated based on photos or videos you provide in order for us to verify your identity |
Institutional Information (if you are an institutional User) | Employer Identification Number (or comparable number issued by a government), Personal identification information for all material beneficial owners of your business |
Financial Information | Bank account number, Purpose of the account, Tax identification number, Income/net assets/wealth verification statements |
Wallet Information | When you sign up to use Archblock Stablecoins or the Archblock Institutional Platform and connect your wallet to your account, we collect your wallet addresses (both sending and receiving) and information related to them |
Transaction Information | Information about the transactions made using our Services, such as anticipated volumes, purpose of the account, the name of your bank, your banking information, the amount, currency and stablecoin preferences, payment method, date, and/or timestamp |
Additional information you submit to us | Communications: Survey responses, information provided to our User Support team |
B. Automatically Collected Personal Information
Information Category | Description |
|---|---|
Browser, and device information | Information about the device, operating system, and browser you’re using other device characteristics or identifiers (e.g. plugins, the network you connect to) IP address |
Product Usage Information | Activity Information: Information about what you view or click on while visiting our Websites and how you use our Services Diagnostic and Troubleshooting Information: Information about how our Services are performing when you use them, i.e. services-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports |
Information from cookies and similar technologies | See our Cookies Policy below for more information |
C. Information We Obtain from Affiliates and Third Parties
Information Category | Description |
|---|---|
Archblock Group of Companies (“Affiliates”) | We may obtain information about you, such as Basic User Information, Transaction Information and Product Usage Information, from our Affiliates as a normal part of conducting business |
Public Database Information | We obtain information about you from a number of external public databases, such as the United Nations Sanctions List, US ITA Consolidated Screening List, the SEC EDGAR, FATF’s “High Risk Jurisdictions subject to a Call for Action” and “Jurisdictions under Increased Monitoring” lists, and high-risk countries lists (based on SRO, FINMA, and SECO sanctioned countries and best practice standards, including your name, address, email address, phone number, gender, national ID number and nationality/country of residence, date of birth, job role, public employment profile, listing on any sanctions lists maintained by public authorities, and other data as necessary |
Blockchain Data | We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses |
Information from Analytics Providers | We receive information about your Website usage, interactions, age group, and survey responses (including prior to account creation, in some cases) |
2. HOW WE USE YOUR INFORMATION
We use your Personal Information to deliver, personalize, operate, improve, create, and develop our Services, and for legal compliance, anti-money laundering, and anti-fraud purposes.
A. Necessary to perform our contract with you
Certain Personal Information is necessary to perform under our applicable Terms of Use or other applicable contracts with you. Your account will be terminated if we cannot process your Personal Information for these purposes.
How and Why We Use Your Information | Information Categories |
|---|---|
To create and maintain your account In order to provide you with our Services, and to allow you to set up a user account and profile. | Basic User Information, Supplemental Identification Information, Financial Information |
To provide you with Services In order to provide you with personalized Services to mint and redeem Archblock Stablecoins, or onboard to the Archblock Institutional Platform. | Basic User Information, Supplemental Identification Information, Financial Information, Institutional Information, Transaction Information, Wallet Information, Preferences, Blockchain Data, Product Usage Information, Additional information you submit to us |
To provide user support To address your request for support in the Apps, via the Website, or by email and to respond to user support and other inquiries, and social support. | Basic User Information, Supplemental Identification Information, Transaction Information, Product Usage Information (including Location Information), Communications |
To send Service communications To send you administrative or account-related communications about our Services, which can include security updates or transaction-related information, through email, telephone, or in-product notifications. You may not opt-out of receiving critical service communications, such as emails sent for legal or security purposes. | Basic User Information, Product Usage Information, Communications, Transaction Information |
To promote the safety, security, and integrity of our Services To verify accounts and related activity, find and address violations of our Terms or policies, investigate suspicious activity, detect, prevent and combat harmful or unlawful behavior, detect fraudulent behavior and to maintain the integrity of our Services, including account takeover (“ATO”) prevention and support. | Basic User Information, Transaction Information, Product Usage Information, Supplemental Identification Information, Institutional Information, Financial Information, Communications, Additional information you submit to us |
B. To comply with our legal obligations
Our Services are subject to laws and regulations requiring us to collect, use, and store your Personal Information in certain ways. We will close your account if you do not provide the necessary Personal Information as is required by law.
How and Why We Use Your Information | Information Categories |
|---|---|
To verify your identity We are generally required to collect various pieces of Personal Information to properly identify or verify your identity and comply with other specific anti-money laundering (“AML”) or sanctions laws/regulations. In order to perform our identification duties under FINMA Circular 2016/7 (“Video and online identification”), our verification processes involve video or online identification through the comparison of your ‘selfie’ against your provided verification information. All such information is securely maintained by the Company and its approved service providers, and is only disclosed where permitted by law. | Basic User Information, Supplemental Identification Information, EIDV Information |
To comply with other legal and regulatory obligations We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with the law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities. Examples of laws that may require us to collect, use or disclose your information: Civil, commercial, criminal, or consumer protection matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings or regulatory inquiries (e.g. orders or mandatory requests under the Irish Competition and Consumer Protection Act 2014, US federal and state consumer protection and privacy laws, subpoenas from any court with jurisdiction, and/or Swiss Federal Act on Data Protection (“DPA”). Corporate and taxation matters: obligations such as the Irish Companies Act 2014 and the Taxes Consolidation Act 1997, and the Internal Revenue Service code. Regulatory matters: to comply with our regulatory obligations, including engaging with our regulators, such as (but not limited to) the U.S. Commodity Futures Trading Commission, the U.S. Securities and Exchange Commission, the UK Financial Conduct Authority, and the Swiss Financial Market Supervisory Authority. | Basic User Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data |
C. For our Legitimate Interests
We rely on our legitimate interests or those of third parties (like our other Users and in some cases, the general public) where they are not outweighed by your rights and freedoms. In the EEA and UK, you have the right to object to, and seek the restriction of, this processing.
How and Why We Use Your Information | Legitimate Interests Relied On | Information Categories |
|---|---|---|
To customize your experience with our Services and otherwise improve our Services We are generally required to collect various pieces of Personal Information to properly identify or verify your identity and comply with other specific anti-money laundering (“AML”) or sanctions laws/regulations (e.g. funds transfer rules). Our verification processes also involve electronic identification through the comparison of your ‘selfie’ against your provided verification information. All such information is securely maintained by the Company and its service providers, and is only disclosed where permitted by law. | It is in our interest to understand how you interact with the Services in order to customize and/or improve our products and Services and enable accurate and reliable reporting. | Basic User Information, Product Usage Information, Transaction Information |
To provide marketing communications to you We use your information to send you targeted marketing communications through email or in-app. | It is in our interest to promote our products and Services that you may be interested in. | Basic User Information, Institutional Information, Product Usage Information, Transaction Information, Information from our Marketing Partners |
We preserve and share information with others, including law enforcement, civil litigants, and others who may issue legal requests Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information:
| It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Services, violations of our Terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, Company personnel and property or the Service), our Users or others, including as part of investigations or regulatory inquiries; to defend our legal rights and resolve disputes; to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences or to prevent death or imminent bodily harm. | Basic User Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data |
To promote safety, security and integrity Outside of performing our contract with you, we may use and analyze your information to protect the integrity of our Services. For example, we may use it to:
| It is in our interest and the interests of our Visitors and Users to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences. | Any of the categories of information listed in Section 1. Information We Collect About You. |
To provide user support To provide communications and user support through our User Support team. | It is in our interest and our Users' interest to provide user support and improve our Services. | Basic User Information, Supplemental Identification Information, Additional Information you submit to us |
D. Based on your consent
When we use your information based on your consent, you have the right to withdraw your consent at any time on a go-forward basis (which will not affect our prior use of your data, based on your previously given consent).
How and Why We Use Your Information | Information Categories |
|---|---|
To enable device-based settings Collecting information that you allow us to receive through the device-based settings you enable (such as access to your GPS location, camera or photos), which we use to provide the features or services described when you enable the setting. | Browser and device information |
To provide marketing communications to you To send you targeted marketing communications through email and in-app messages. | Basic User Information, Institutional Information, Product Usage Information, Transaction Information, Information from our Marketing Partners, Additional information You Provide to Us |
E. To protect your vital interests
How and Why We Use Your Information | Information Categories |
|---|---|
Preserving, reviewing, and sharing information with law enforcement and others We may preserve, review, and share information with law enforcement and others in circumstances where someone’s vital interests require protection, such as in the case of emergencies. For example, where there is a risk to the well-being or life of a User. | Basic User Information, Supplemental Identification Information, Institutional Information, Wallet Information, Transaction Information, Product Usage Information, Communications Information, Blockchain Data |
The legal bases on which we rely in your country may differ from those listed above if you reside outside the United Kingdom or EEA.
3. WHY AND HOW WE SHARE YOUR INFORMATION
We work with service providers, partners and other third parties to help us provide our Services, and as a result, we need to share certain information with these third parties. Here’s how:
A. Affiliates
Personal Information that we process and collect may be transferred between companies, Services, and employees affiliated with us as a normal part of conducting business and offering our Services to you.
B. Linked Third-Party Content Providers and Third-Party Websites
When you use third-party services (like when you connect your account with your bank account), websites that are linked through our Services, or create an account with a Third-Party Content Provider (as defined in our Terms), the providers of those services or products may receive information about you that the Company, you, or others share with them. Please note that when you use these third-party services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.
C. Professional advisors, industry partners, authorities, and regulators
We share your information described in Section 1. Information We Collect about You with our advisors, regulators, tax authorities, law enforcement, government agencies, and industry partners to:
respond pursuant to applicable law or regulations, court orders, legal processes or government requests;
comply with our reporting and information sharing obligations with industry partners and regulatory authorities;
detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and
protect the rights, property, and safety of our Users, the Company and its Affiliates, or others, including to prevent death or imminent bodily harm.
D. Asset Transfer or Company Acquisition
We may choose to buy or sell assets and may share and/or transfer information about our Users in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your Personal Information could be one of the assets transferred to the acquiring party.
E. Third-Party Service Providers
We work with third-party service providers to help us provide our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process as necessary for the purpose of the contract. We work with different types of third-party service providers, including:
Types of Third-Party Providers We Use | What Information We Share |
|---|---|
| Basic User Information, Supplemental Identification Information, EIDV Information, Institutional Information, Usage Information, Transaction Information, Blockchain Data, Wallet Information, Additional information you submit to us |
4. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We retain your information as needed to provide our Services, comply with legal obligations, or protect our or others’ interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Users, and Visitors.
We retain biometric information (as part of our retention of Supplemental Identification Information) for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third-party electronic identity verification service providers retain this information for as long as set out in their applicable notices/policies.
In line with these considerations, we delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your information (which you can initiate by contacting us here: [email protected].)
We employ reasonable technical and organizational measures to retain and help protect your Personal Information from compromise, as required by applicable data protection laws.
5. CHILDREN’S PERSONAL INFORMATION
The Websites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any Personal Information through the Websites or Services. If a Visitor or User submitting Personal Information is suspected of being younger than 18 years of age, the Company will require the relevant User or Visitor to close his or her account, and will take steps to delete the individual’s information as soon as possible.
6. INTERNATIONAL TRANSFERS
To facilitate our global operations, the Company, its Affiliates, third-party partners, and service providers may transfer, store, and process your Personal Information throughout the world, including Ireland, Switzerland, the Cayman Islands, and the US.
If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your Personal Information (collectively, “European Personal Data”). By providing Personal Information to us, you consent to the transfer of your Personal Information to such third countries. To the extent applicable, we have adopted appropriate transfer mechanisms to safeguard the transfer of your Personal Information in accordance with applicable laws, including, the European Commission’s Standard Contractual Clauses.
For a copy of the Standard Contractual Clauses, please contact [email protected].
In addition, we may rely on certain exemptions provided for under data protection law for our international transfers. We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law. For example, because the Company operates and provides its Services globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Services (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing Personal Information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).
7. YOUR PRIVACY RIGHTS
Depending on where you live, you may be able to exercise certain privacy rights related to your Personal Information. For any of your privacy rights and choices referenced below, requests relating to your Personal Information can be made by submitting a request by contacting us at [email protected]. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, the Company has absolute discretion in providing you with these rights.
Right to access and portability:
You may request that we provide you a copy of your Personal Information held by contacting us at [email protected].Right to rectification:
You may request us to rectify or update any of your Personal Information held by the Company that is incomplete or inaccurate by contacting us at [email protected].Right to deletion/erasure:
You may request to erase your Personal Information, subject to applicable law, by contacting us at [email protected]. If you close your account, we will retain or delete information associated with your account.Right to withdraw your consent:
To the extent the processing of your Personal Information is based on your consent, you may withdraw your consent at any time. The lawfulness of the Company’s processing before you withdraw your consent will not be affected by such withdrawal.Right to object to or restrict processing:
You may have the right to restrict or object to us using or transferring your Personal Information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your Personal Information where permitted or required by applicable law. You can opt-out of receiving marketing communications from the Company by contacting us at [email protected].Right to non-discrimination:
We will not discriminate against you for exercising any of your rights provided to you under law.Right to lodge a complaint:
If you reside in the EEA, Switzerland, or the UK, you have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or state. In the UK, the relevant data protection authority is the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, +44 (0303) 123 1113, email: [email protected]. In Ireland, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: [email protected].
To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.
These rights are not absolute and may be denied: (a) when granting access or assisting portability would adversely affect the rights and freedoms of others; (b) to protect our rights and properties; (c) where the request is frivolous or vexatious; or (d) as otherwise permitted by law.
8. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This California Privacy Notice (“Notice”) is for California residents, and describes how we collect, use, and share your Personal Information. This Notice supplements our Privacy Policy. Any terms defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (“CCPA”) have the same meaning when used in this Notice.
The CCPA, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with you.
Sources of Personal Information. We gather various types of Personal Information from our users, individuals who access or use our Services, from a range of sources, such as:
information you give us when you sign up for, or otherwise use our Services;
information we receive from our Affiliates and third parties; and
information we collect automatically through cookies and similar technologies (see our Cookie Policy for more information on this type of information).
Purpose for Collection and Disclosure of Personal Information. We’ve collected and disclosed the below categories for Personal Information to create, develop, operate, deliver, and improve our Services, to communicate with you, to ensure the safety, security and integrity of our Services, and for the business and commercial purposes. We do not collect, use, or disclose sensitive Personal Information for purposes other than those specified in this privacy policy, to provide the Services, or as permitted under applicable law.
Collection and Disclosure of Personal Information. In the past 12 months, we may collect, and have collected, the below categories of Personal Information, and disclosed the specific types of Personal Information below (as that data is further referenced and outlined herein) with the following categories of third parties:
Category of Personal Information as outlined in the CCPA | Information Collected and Disclosed | Categories of Recipients |
|---|---|---|
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
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Personal information described in subdivision (e) of Section 1798.80 (e.g., name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information) |
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Protected classifications under California and federal law, including gender, age, and citizenship |
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Biometric information |
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Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement |
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Geolocation data |
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Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information (e.g., recorded meetings and phone calls) |
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Professional or employment related information |
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Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; interaction data collected about you when you interact with us such as websites or mobile apps including log data (information collected when you access our website including IP address, URLs and crash data), device data (information about your device including type, operating system and unique identifiers), browser data (information about your browser type, settings cookie data) |
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Collection and Disclosure of Sensitive Personal Information. In the past 12 months, we may collect, and we have collected and disclosed the following categories of sensitive Personal Information, with the following categories of third parties:
Category of Personal Information as outlined in the CCPA | Information Collected and Disclosed | Categories of Recipients |
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Sensitive identifier (e.g., social security number, driver’s license, state identification card, or passport number) |
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Account information (e.g., account log-in, financial account, password, or credentials allowing access to an account |
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Communications content (e.g., mail, email, and text messages unless the business is the intended recipient of the communication) |
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Biometric information processed for the purpose of unique identification |
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Retention period or criteria. We retain California resident Personal Information for a period commensurate with the purposes for which the Personal Information was collected or obtained. For example, the criteria used to determine the retention of Personal Information includes any time necessary to complete a transaction or for legal and compliance purposes or security purposes. Personal Information may be retained in archival format (e.g., data backups) beyond its retention period so long as it is not subject to further access.
Selling or Sharing of Personal Information. [In the past 12 months, we’ve shared (as that term is defined in the CCPA, as amended by the California Privacy Rights Act of 2020, and the CCPA Regulations) identifiers with third party service providers.
We do not have actual knowledge that we sell or share Personal Information of individuals under 16 years of age.
California Privacy Rights. Under the CCPA, eligible California residents may be entitled to certain privacy rights, including:
Right to Know. You may have the right to access the Personal Information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format.
Deletion. You may have the right to request that we delete any of the Personal Information we have collected or maintain about you.
Correction. You may have the right to correct inaccuracies in your Personal Information.
Opt-out of the “Sale” and “Sharing” of Personal Information. You may have a right to opt-out of the “sale” and “sharing” of your Personal Information.
Sensitive Personal Information. You may have the right to opt-out of the use and disclosure of your sensitive Personal Information in certain circumstances.
Restrict Profiling. You may have the right to restrict the use of your Personal Information for the purposes of profiling.
Portability. You may have the right to obtain a copy of certain Personal Information in portable (e.g., machine readable) format.
Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your California privacy rights, such that you will not be denied goods or services, charged a higher rate, or provided with lower quality products or services.
Exercising Your Rights. You may exercise your rights by contacting us at [email protected] and then verifying your identity (a “Verifiable Consumer Request”). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may collect information such as your email address, government issued ID, or date of birth, before providing a substantive response to the request.
We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and up to twice in twelve (12) months. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided you receive notification of the extension within the first forty-five (45) days.
You may send us an email at [email protected] to request access to, correct, or delete any Personal Information that you have provided to us. Should you feel that your data is processed in breach of data protection law or other legislation, you can report your concern to us by emailing us at [email protected].
California “Shine the Light” Law. We do not share Personal Information, as defined by Cal. Civ. Code § 1798.83, with third parties for their direct marketing purposes.
Questions & Opting-Out. If you have questions or concerns regarding this Notice, if you want to request to opt-out of the sale or sharing of your Personal Information, or if you have a complaint, please contact us at [email protected].
9. U.S. STATE CONSUMER PRIVACY RIGHTS
Residents of the U.S. states of Colorado, Connecticut, Utah, and Virginia may have the following rights:
Access. You may have the right to access the Personal Information collected about you.
Deletion. You may have the right to request that we delete any of the Personal Information we have collected or maintain about you.
Correction. You may have the right to correct inaccuracies in your Personal Information.
Opt-out of the “Sale” of Personal Information, Profiling, and/or Targeted Advertising. You may have a right to opt-out of the “sale” of your Personal Information, profiling, and/or the use of your Personal Information for targeted advertising.
Opt-in to Disclosure of Sensitive Personal Information. You may have the right to consent (opt-in) prior to the use and disclosure of your sensitive Personal Information in certain circumstances.
Portability. You may have the right to obtain a copy of certain Personal Information in portable (e.g., machine readable) format.
Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your privacy rights.
10. COOKIE POLICY
We use cookies and similar technologies. This Cookie Policy explains how we use cookies in connection with the Website, Services, and your related choices.
What Types of Cookies Do We Use?
Cookies are small text files that collect standard Internet log information and visitor behavior information. Cookies are stored in your web browser and allow certain websites to retrieve stored information later. When you visit our websites, we may collect information from you automatically through cookies or similar technology (collectively "Cookies").
There are a variety of different types of cookies. Our Website uses:
Strictly Necessary or Essential Cookies: These cookies are necessary for the Website to function and cannot be switched off in our systems. We have to load essential Cookies to deliver our Website's necessary functionality to you.
Functionality Cookies: These cookies are used to enable additional functionality on our Website, such as storing your preferences (e.g., username) and assisting us in providing support or services.
Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources to measure and improve our Websites’ reliability and performance. Performance cookies help us with our analytics, including compiling statistics and analytics about your use of and interaction with this Website, and monitoring for errors.
You can learn more about Cookies at https://allaboutcookies.org/.
11. HOW TO CONTACT US WITH QUESTIONS
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at [email protected].
You can also file a complaint to your respective data protection authority in the EU, UK, or California.
12. CHANGES TO THIS PRIVACY POLICY
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page. If your consent is required for any such changes, we will obtain your consent before such changes are applied to you.
Your Comments and Concerns
All feedback, comments, requests for technical support and other communications relating to the Website and Services should be directed to: