Last Updated: August 8, 2023
2. PERSONAL INFORMATION THAT WE COLLECTThe categories of personal information we collect depend on how you interact with us, our Turnkey Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Turnkey Services, and information from other sources such as third-party services and organizations, as described below.
A. Personal Information You Provide to Us Directly We may collect personal information that you provide to us.
● Account Creation. We may collect personal information when you create an account, such as email address, wallet addresses, name, and account name.
● Protocol Payloads, Wallet and other Output Information. In order to utilize some of the Turnkey Services, you may need to provide us with information about your wallet(s) including the types and amounts of digital assets on the blockchain you possess and details about Protocol payloads into which you have entered. We will never ask you for your private keys, API keys, or authenticators.
● Your Communications with Us. We may collect personal information, such as names and email addresses, when you request information about our Turnkey Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
● Interactive Features. We and others who use our Turnkey Services may collect personal information that you directly submit to us through our interactive features.
B. Personal Information Collected Automatically We may collect personal information automatically when you use our Turnkey Services.
● Automatic Collection of Personal Information. We may collect certain information automatically when you use our Turnkey Services, such as your internet protocol IP address, user settings, MAC address, information about the browser, operating system and device you’re using, device characteristics and identifiers, location information (including approximate location derived from IP address), and internet service provider. We may also automatically collect information regarding your use of our Turnkey Services, such as pages that you visit before, during and after using our Turnkey Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Turnkey Services.
○ Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.
● Analytics. We may use Technologies and other third-party tools to process analytics information on the Turnkey Services. These Technologies allow us to better understand how our digital Turnkey Services are used and to continually improve and personalize the Turnkey Services. Some of our analytics partners include:
C. Personal Information Collected from Other Sources We may collect personal information from other sources when you use our Turnkey Services.
● Blockchain Networks. We may independently collect personal information from blockchain networks that we have access to. This personal information may include public wallet addresses and details about transactions carried out on the applicable blockchain network.
3. HOW WE USE YOUR PERSONAL INFORMATIONWe use your personal information for a variety of business purposes, including to provide our Turnkey Services, for administrative purposes, and to market our products and Turnkey Services, as described below. A. Provide Our Turnkey Services We use your information to fulfill our contract with you and provide you with our Turnkey Services, such as to:
● Determine your eligibility to use the Turnkey Services;
● Create and maintain your account;
● Respond to your comments, questions and requests and provide customer service;
● Provide and deliver the products and services you request;
● Process transactions and provide you related information, including invoices, confirmations and receipts;
● Provide support and assistance for the Turnkey Services; and
● Provide, maintain and improve our Turnkey Services. We use your information where it is in our legitimate business interests to do so, such as to:
● Send you technical notices, updates, security alerts and support and administrative messages;
● Monitor and analyze trends, usage and activities in connection with our Turnkey Services;
● Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Turnkey and others;
● Personalize and improve the Turnkey Services and provide content or features that match user profiles or interests;
● Ensure and improve the security of our website and the Turnkey Services; and
● Link or combine with information we get from others to help understand your needs and provide you with better service.
B. Marketing our Products and Turnkey ServicesAs permitted by applicable law — and unless your consent is required — it is in our legitimate business interests to use personal information to tailor and provide you with content (including about our products, services, news and information) via email. 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 in “Contact Us” below or by following the unsubscribe link provided in each email.
C. With Your Consent We may use personal information for other purposes where you provide your consent.
D. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law, including where such purposes are clearly disclosed to you at the time you provide your personal information.
● De-identified or Aggregated Information. We may use personal information to create de-identified, anonymized and/or aggregated information, such as demographic information, information about the device from which you access our Turnkey Services, or other analyses we create.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATIONWe disclose your personal information to third parties for a variety of business purposes, including to provide our Turnkey Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Turnkey Services The categories of third parties with whom we may share your personal information are described below.
● Notice Regarding Use of Blockchain Networks. Information about transactions you enter into via the Turnkey Services will be recorded on the blockchain and may be accessible to third parties due to the public nature of the blockchain. Because entries to the blockchain are, by their nature, public, and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the blockchain could possibly be used to identify you, or information about you.
● Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Turnkey Services or who otherwise perform business-related functions for Turnkey. This includes:
○ Third-party Protocol participants;
○ Technology, hosting and telecommunications vendors and IT support;
○ Compliance and security risk assessment service providers;
○ Support and customer service vendors;
○ Payment processing companies, such as Stripe;
○ Vendors providing accounting, auditing, tax, legal, and other professional services; and
○ Analytics providers.
● Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
● Affiliates. We may share your personal information with our company affiliates.
B. 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: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. 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, your information may be disclosed, sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTSYour Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
● “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.
Your Privacy Rights. In accordance with applicable law and depending on your location, you may have the right to:
● Access to, and Portability of, Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format;
● Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
● Request Deletion of your personal information;
● Request Restriction of or Object to our processing of your personal information; and
● Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal. If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
7. INTERNATIONAL DATA TRANSFERSYou transfer your personal information directly to us in the United States. All information processed by us may be further 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. We will safeguard your information consistent with the requirements of applicable laws.
● Categories of and specific pieces of personal information we have collected about you.
● Categories of sources from which we collect personal information.
● Purposes for collecting personal information.
● Categories of third parties with whom we share personal information.
● Categories of personal information disclosed about you for a business purpose.
● If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold. Right to Delete. You also have a right to request that we delete personal information, subject to certain limitations under applicable law. Right to Opt-out From Sale. You may request to opt-out of any “sale” of your personal information that may take place. We do not rent or sell personal information and take care to not enter into any data sharing arrangements that could constitute a "sale" under the CCPA. Non-discrimination We will not discriminate against you for exercising any of your rights under the CCPA.
10. CHILDREN'S INFORMATIONThe Turnkey Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.