Effective Date and Changes to 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).
The Information We Collect About You
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 ACDX 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 governmental authorities. 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.
Information We Collect Automatically.
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.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our Sites, App and trading platform to you, to process transactions requested by you on our trading platform, to communicate with you about your use of our Sites, App, trading platform, or participation in the Token Sale, to respond to your inquiries, and for other customer service purposes.
- To process and transmit the content that you elect to share through the Sites and App, and to track your physical location if you have permitted geo-location tracking through the App as described above.
- To authenticate Site users and verify the identity of Token Sale participants for the purpose of complying with KYC/AML obligations.
- To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using our Sites or App.
- For marketing, sales and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Sites, App and related services on third party websites.
- To conduct product research and development and perform related activities in order to improve our services.
- To better understand how users access and use our Sites and App, both on an aggregated and individualized basis, in order to improve our Sites and App and respond to user desires and preferences, and for other research and analytical purposes.
- How We Share Your Information
- We may share your information, including personal information, as follows:
- We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Sites and App to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
- Service Providers. We may disclose the information we collect from you to third party service providers, contractors or agents who perform functions on our behalf, such as our KYC/AML service provider and Amazon Web Services.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
- To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties and publicly for marketing, advertising, research or similar purposes.
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 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.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Sites. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Sites.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
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.
Third Party Analytics
Security of My Personal Information
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.
Access To My Personal Information
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 firstname.lastname@example.org. 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.
Location of Personal Information
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.
Choices Regarding Your Personal Information
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.
Children Under 13
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 email@example.com.
Additional European Union Disclosures
We are the data controller of your personal information collected pursuant to this Policy.
Legal Basis for Processing Your Information
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 firstname.lastname@example.org.
Retention of Your Information
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 email@example.com to opt out.
Data Protection Authority
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 Obligations to Provide Information
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.
Requests Regarding Your Information
You may contact us at any time using the contact details provided in the “Contact Us” section above:
- If you want to rectify your inaccurate personal data.
- If you want us to erase your personal data from our records, in the event grounds for erasure applies according to applicable privacy law.
- If you want to restrict our processing of personal data, in the event grounds for such restriction applies according to applicable privacy law.
- If you want to receive the personal data concerning you which you have provided to us, in a commonly used and machine-readable format (Data Portability), according to applicable privacy law.
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.