By visiting the Sites, or by downloading and using the App, you agree that your personal information will be handled as described in this Policy. Your use of our Sites or App, participation in the EMX token sale (the “Token Sale”), and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Terms of Service are incorporated by reference into this Policy.
This Policy is current as of the Effective Date set forth above. Please note that we may change this Policy from time to time and will post any such changes to this Policy on the Sites. Therefore, it is important to view the Policy periodically. If we make any changes to this Policy that materially affect our practices, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites or if you have an account with us, providing notice to the email address in your account (for this reason you should make sure to update your account information promptly if it changes).
We collect information about you directly from you and from third parties, as well as automatically through your use of our Sites or App.
Information We Collect Directly From You. You may browse certain areas of the Sites without registering with us or providing us personal information. If you complete our registration form on the Sites, we will collect your name and email address. If you create an account on the Sites, we will collect your name, date of birth, gender, citizenship information, address, telephone number and a copy of your passport or identification card. To verify your identity, images of your form of identification will be collected by a third party on our behalf and will be stored on their systems. We may request your social security number / national identity number and obtain a copy of your credit history or credit reports from credit reporting agencies in order to provide access to certain of our services. If you download the App, we will collect at a minimum your name, email address, mobile telephone number and user name. If you purchase EMX tokens (“Tokens”) in the Token Sale, we will collect your Ethereum EIP-20 wallet address or any other compatible wallet address as required to participate in the Token Sale. We may require certain personal identification information for the purpose of complying with know-your-customer and anti-money laundering (“KYC/AML”) obligations, including regulations implemented by the Financial Crimes Enforcement Network, or the screening of prohibited persons pursuant to the list of Specially Designated Nationals and Blocked Persons published by the U.S. Office of Foreign Assets Control (“OFAC”) or any similar or comparable list of banned persons issued by any U.S. or other governmental authority. Know-your-customer information may include, but is not limited to, your name, address, date of birth, passport and copies of utility bills or other identifying documents and additional financial information related to your accredited investor status.
You may be able to access the Sites or App through your social media accounts, such as Facebook and Google. If you access the Sites or App using a social media account, the account will ask your permission to share certain information with us. This may include your first name, last name, social media identifier, age, birthday, gender, locale, timezone and email address. This also may allow us to obtain information from those accounts (such as your friends or contacts). The information we obtain from social media accounts often depends on your settings in the social media platform or the social media platform’s privacy policies, so be sure to check them. For example, any information collected by Facebook or Google is provided to us under the terms of their respective privacy policies. You are responsible for keeping your account login credentials, including any social media login credentials, confidential. You should not share such login credential with any other person as you are responsible for all activity on your account. You will immediately notify us if you are aware or suspect any unauthorized use of your account.
Geolocation. If you have provided permission through your mobile device to allow us to collect location information through the App, we may obtain your physical location information from technologies like GPS, Wi-Fi, or cell tower proximity. The App may use the geo-location features of the App (GPS or network-based) and geo-location information that is collected through the App and your mobile device, to track your location and provide you information regarding the physical world around you. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device's location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.
We use your information, including your personal information, for the following purposes:
We may share your information, including personal information, as follows:
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Sites and App.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and App, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and App. There are two types of cookies: session and persistent cookies.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will not be able to browse certain areas of the Sites or use the App.
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
You may access, update and delete your personal profile in the account associated with the Sites and App at any time. You may also request copies, modifications or deletions of personal information that you have submitted to us by contacting us at email@example.com. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Sites for a period of time.
We store any personal information or data we collect from users within the European Union. If you access the Sites or App from outside the European Union, you consent to the transfer, processing and storage of your personal information in and to the European Union, which may provide protection for your personal information that varies from the protection provided by the jurisdiction in which you reside.
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or use of the Sites or the App, including in-App messages regarding updates or upgrades to the App.
Our Sites and App are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
If you have questions about the privacy aspects of our Sites or App or would like to make a complaint, please contact us at firstname.lastname@example.org.
We are the data controller of your personal information collected pursuant to this Policy.
The legal bases for the processing of your personal information include your consent and necessity for performance of a contract for any services we provide to you and any Tokens you purchase in the Token Sale. In addition, we rely on our legitimate commercial interest providing our services to you and in selling Tokens in the Token Sale in order to process your information as described in this Policy. The legal basis for sending marketing materials to you is your consent and our legitimate commercial interest in providing you with information regarding our services. Any consent you provide may be withdrawn at any time by contacting us at email@example.com.
We will store your personal information until you no longer maintain an account on our Sites and App. If we are required by law to retain your information longer or if your information is required for us to assert or defend against legal claims, we will retain your information until the end of the relevant retention period or until the claims in question have been settled. Please note that if you opt out of our retention of your data, we may not be able to provide or complete the services offered on our Site, including the Token Sale. You may contact us at firstname.lastname@example.org to opt out.
If you believe that we are not processing your personal information in compliance with this Policy or applicable data protection laws, you have the right to lodge a complaint with the local data protection authority in your jurisdiction or our supervisory authority in the European Union.
Your provision of your personal information under this Policy primarily results from contractual requirements in order to make our Sites, App, and the Token Sale available to you. In certain circumstances, statutory requirements may require us to collect personal information from you. Failure to provide personal information may result in your inability to access our Sites or App, or to participate in the Token Sale.
If you do not wish to receive email marketing communications from us, you can click the unsubscribe link in the relevant email. This will allow you to remove yourself from that particular email mailing list. You can do this for each of our email marketing communications. You can opt-out of all communications except for certain service related messages, such as order confirmations or important account-related messages.
You may contact us at any time using the contact details provided in the “Contact Us” section above:
For your protection, we will ask you for proof of your identity before making your personal data available to you. We may have to keep certain information required by law and/or for our own legitimate business purposes.