Findora Privacy Notice
Effective Date: August 1, 2020
This Privacy Notice applies to personal information processed by The Findora Foundation and Findora Development Pte. Ltd (“Findora,” “we,” “us,” and “our”) in the course of our business, as collected from users who store and manage Digital Assets and use the Findora Wallet (each a “User”), developers who use the Findora Network to build and host their own applications (each a “Developer”), our website, our applications, and our related online and offline offerings (collectively, the “Services”).
All capitalized terms not defined in this Privacy Notice will have the meanings set forth in the Findora Terms of Service or Findora License and Services Agreement.
PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depends on how you interact with our Services.
Information You Provide to Us.
Account Information. When you create an account with Findora, we collect information such as your name, email address, phone number, and other information.
Digital Assets. The Services allow Users to manage various Digital Assets, such as transaction records and data, stock certificates, cryptocurrency, identity, or anything else that you deem valuable or upload to the Services.
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We may offer forums, blogs, chat and messaging services, and social media pages. Findora and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and will not be subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.
Customer Service and Support. If you call or otherwise interact with Findora’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Findora and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Findora.
Information Collected Automatically.
Findora Wallet. If you are a User with a Digital Wallet, we will initially provide you with a wallet address (also referred to as a “public address”) and subsequently collect your wallet address as you use the Services. We will also collect information about your Digital Wallet including the types and amounts of Digital Assets on the blockchain you possess and details about transactions into which you have entered.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may also use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the website by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources.
Our Developer Customers. If you use our Services on behalf of an organization (e.g., your employer), that organization may provide us with information about you so that we can provision your account.
Third Party Services and Organizations. We may obtain information about you from other sources, including through third party services and organizations. For example, if you access our Services through a third-party application, such as a third-party login service or a social networking site (e.g., Google, GitHub, WeChat), we may collect information about you from that third-party application that you have made available via your privacy settings.
HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to:
To provide the Services or Information Requested.
Fulfill our contract with you or the organization on whose behalf you use the Services;
Manage your information;Respond to questions, comments, and other requests; Process payment card and/or other financial information to facilitate your use of the Services; Provide access to certain areas, functionalities, and features of our Services; and Answer requests for customer or technical support. Administrative Purposes.
Pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention; Measure interest and engagement in the Services;
Develop of new products and services; Improve our products and Services; Ensure internal quality control and safety; Verify individual identity; Carry out audits; Communicate with you about activities on the Services and changes to our agreements; Prevent and prosecute potentially prohibited or illegal activities;
Enforce our agreements; and Comply with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. Findora may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
If you have any questions or concerns about how Developer Data is handled or would like to exercise your rights, you should contact the Developer who has contracted with us to use the Services to process the Developer Data.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
Notice Regarding the Use of Blockchain. The transactions records and senders and receivers of transactions associated with your Digital Assets, Findora Wallet, and the Findora Network address may be publicly available on the blockchain. As a result, information about your transactions and the senders and receivers of your transactions will be accessible to third parties due to the nature of the blockchain.
Other Individuals or Organizations at your Instruction. Through your use of the Services, you may instruct us to share some of your personal information with an individual or organization that you want to interact with. We are not responsible for the privacy or security practices of these third-party recipients.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for:(i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Your Organization. If you use our Services on behalf of an organization (e.g., your employer), that organization may: (i) access information associated with your use of the Services including usage and other data and the contents of the communications and files associated with your account; (ii) control and administer your account, including controlling privacy-related settings (e.g., profile settings including choices relating to displaying a profile image); and (iii) access and control of Developer Data (as stated above, Developer Data is outside the scope of this Privacy Notice).
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share personal information with our subsidiaries and affiliates.
Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your personal information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.
You may have the right to object to or opt out of certain uses of your personal information.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Notice).
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device.
INDIVIDUAL RIGHTS IN PERSONAL INFORMATION
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by Findora, subject to certain exceptions prescribed by law and technical restrictions inherent in the blockchain. If you would like to exercise any of these rights, please log into your account or contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you are a California resident, you have the right not to receive discriminatory treatment by Findora for the exercise of your rights conferred by the California Consumer Privacy Act.
Please note that if you use our Services on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the rights listed above.
We store the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Please note that due to technical restrictions inherent in the blockchain, deletion of some of your information may not be possible.
SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
THIRD PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.
You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time at our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
If you have any questions about our privacy practices or this Privacy Notice, please contact us at: firstname.lastname@example.org