EXODUS MOVEMENT, INC.
PRIVACY POLICY
Last Reviewed and Updated: May 9, 2025
California Notice at Collection/State Law Privacy Rights: See theState Privacy Rights Noticesection
below for important information about your rights under applicable state privacy laws.
Exodus Movement, Inc. and its subsidiary, Proper Trust AG (collectively,“Exodus,” “we,”
“our,”and/or“us”), values the privacy of individuals who use our websites (including exodus.com
and https://passkeys.foundation/ and https://www.sayecho.xyz (the“Sites”)), applications, or
services, including the blockchain currency management software that is downloadable from the
Sites(including Camino and Exodus wallets), and any services that link to this Privacy Policy
(collectively, our“Services”). This privacy policy (the“Privacy Policy”) explains how we collect, use,
and disclose Personal Data from users of our Services. For the purposes of this Privacy
Policy,“Personal Data”means information that relates to an identified or identifiable natural person.
Notice to European Users: Please see theNotice to European Userssection below for additional
information for individuals located in the European Economic Area or United Kingdom (which we
refer to as“Europe”, and“European”should be understood accordingly).
By using our Services, you agree to the collection, use, and disclosure of your Personal Data as
described in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to
ourTerms of Use.
As the Exodus Wallet is a non-custodial crypto asset software wallet, we do not have customer
accounts. We do not require you to provide your Personal Data to us to use the Exodus Wallet. If
you sign up for our newsletter, certain beta programs and services, or provide your Personal Data in
a customer service ticket or in connection with an advanced customer service program, that
information will be collected by us. However, certain third- party API providers may require you to
provide them with Personal Data, in order to use their services through the Exodus Wallet.
INFORMATION WE COLLECT
Exodus aims to collect as little Personal Data from users as possible to ensure a completely private
and anonymous user experience when using our Services. However, we may collect limited Personal
Data from or about you or your devices from various sources, as described below.
Information You Provide to Us Through the Sites.When you contact us, sign up for our newsletter,
sign up for advanced customer service, or if you choose to participate in certain beta programs and
other services we provide, we collect any Personal Data you provide to us, such as your name, email
address, social media user ID and display name, and country of residence.
Information We Collect Automatically Through the Sites.We may automatically collect information
about you and your devices when you use our Sites. For example, when you visit our Sites, we collect
your internet protocol (IP) address, web browser type, web browser language, operating system type,
the website you visited before browsing to our Sites, a pseudonymous User ID that is unique to
Exodus for Exodus’s internal use in improving its products and services, the pages you view, the
length of time you spend on a page, the dates and times of your visits, the hyperlinks you click on,
and other information about your use of our Sites. When performing an exchange through a
third-party API provider or when creating an Echo account, we log information such as the wallet
addresses and the transaction IDs involved (if any).
Service Interaction Data.We may automatically collect pseudonymous data corresponding to your
interactions with our blockchain currency management software, such as event data and software
feature usage and analytics data, which we use for security purposes, to verify the functionality of
features in the Services, and to improve our Services.
Cookies.We and the third-party API providers may collect information through our Sites using
cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics or advertising
partners, may use these technologies to collect information about your online activities over time
and across different websites. Cookies are small text files containing a string of alphanumeric
characters. A pixel tag is a single pixel, transparent GIF image with a unique identifier that can
recognize certain types of data on your device (similar to how cookies do). When we refer to
“cookies” in the remainder of this Privacy Policy, such reference includes cookies, pixel tags, or
similar technologies deployed on our Sites.
We may use both session cookies and persistent cookies. A session cookie disappears after you
close your browser. A persistent cookie remains after you close your browser and may be used by
your browser on subsequent visits to our Site.
Our Sites use the following types of cookies for the purposes described below:
● Functional Cookies.We use functional cookies to recognize you when you return to our
Sites.
● Analytics and Performance Cookies.We use analytics and performance cookies for website
analytics purposes to operate, maintain, and improve the Sites. We also use analytics
cookies for attribution purposes to understand how you learned of the Services. The
information gathered by these cookies is aggregated and anonymized and does not identify
any specific individual visitor. We use Google Analytics to collect and process certain
analytics data on our behalf. Google Analytics uses its own cookies that help us understand
how you engage with the Sites and may also collect information about your use of other
websites, apps, and online resources. The links below provide additional information and
resources for Google Analytics:
o Google Analytics
o Prevent the Use of Google Analytics in connection with your use of our Services
● Advertising Cookies.We may allow third-party advertising partners to use cookies on the
Sites to collect information about your browsing activities over time and across websites.
For example, our advertising partners, which may include Meta, TikTok and X (formerly
known as Twitter), may deploy pixel tags on our Sites for interest-based advertising
purposes. Using the Meta, TikTok and X pixel tags, we (and Meta, TikTok, and X on our
behalf) may collect information about you such as your visits to the Sites, webpages viewed,
clicks, form submissions, downloads, sign-ups and other browsing activities. We use this
information to understand the effectiveness of, and improve, our interest-based advertising
campaigns, and for the other applicable purposes detailed in this Privacy Policy. The links
below provide additional information and resources regarding interest-based advertising
facilitated by Meta, TikTok, and X:
o Meta
o TikTok
o X
Further information about cookies, including how to see what cookies have been set on your device
and how to manage and delete them, visitwww.allaboutcookies.org.
You can block cookies by setting your internet browser to block some or all of the cookies. However,
if you use your browser settings to block all cookies (including essential cookies) you may not be
able to access all or parts of our Sites. You can change your browser settings to block or notify you
when you receive a cookie, delete cookies or browse our Sites using your browser’s anonymous
usage setting. Please refer to your browser instructions or help screen to learn more about how to
adjust or modify your browser settings. If you do not agree to our use of cookies or similar
technologies which store information on your device, you should change your browser settings
accordingly. You should understand that some features of our Sites may not function properly if you
do not accept cookies or these technologies. Where required by applicable law, you will be asked to
consent to certain cookies and similar technologies before we use or install them on your computer
or other device.
Information We Collect from Other Sources.We may receive Personal Data about you from third
parties, such as data or marketing partners, or we may collect public blockchain data that can be
tied to crypto wallets. We may combine this data with other Personal Data we have about you and
otherwise use it as described in this Privacy Policy.
HOW WE USE THE PERSONAL DATA WE COLLECT
We use the Personal Data we collect for the following purposes:
● To provide, maintain, debug, improve, and enhance our Services.
● To understand and analyze how you use our Services and develop new products, services,
features, and functionality.
● To communicate with you, provide you with updates and other information relating to our
Services, provide information that you request, provide you with our newsletter, respond to
comments and questions, and otherwise provide customer support.
● For marketing purposes, such as developing and providing promotional and advertising
materials that may be useful, relevant, valuable, or otherwise of interest to you.
● To personalize your experience on our Sites such as identifying you as a repeat visitor.
● To facilitate the connection of third-party services or applications.
● To create pseudonymous, de-identified and/or aggregated data to improve for our business
purposes, including to improve our Services.
● To find and prevent fraud, detect security incidents, and respond to trust and safety issues
that may arise.
● For compliance purposes, including enforcing our Terms of Use or other legal rights, or as
may be required by applicable laws and regulations or requested by any judicial process or
governmental agency.
● To contract with third-party API providers, including providing customer service, verifying
customer information, providing advertising or marketing services, providing analytic
services or providing similar services on behalf of the business or service provider.
● For other purposes for which we provide specific notice at the time the Personal Data is
collected.
HOW WE SHARE THE PERSONAL DATA WE COLLECT
We do not share or otherwise disclose Personal Data we collect from or about you except as
described below or otherwise disclosed to you at the time of collection.
● Affiliates.We may share any information we receive with our affiliates and subsidiaries for
any of the purposes described in this Privacy Policy.
● Advertising Partners.We may share your Personal Data with third-party advertising
companies for the interest-based advertising purposes described above.
● Authorities and Others.We may disclose your Personal Data to law enforcement,
government authorities, and private parties if we believe doing so is required or appropriate
to: (i) comply with applicable laws; (ii) respond to law enforcement requests and legal
process, such as a court order or subpoena; or (iii) protect the rights, property, and safety of
Exodus, our employees, agents, customers, and others, including to enforce our agreements,
policies, and Terms of Use.
● Business Transferees.We may transfer your Personal Data to service providers, advisors,
potential third-party API providers, or other third parties in connection with the consideration,
negotiation, or completion of a corporate transaction in which we are acquired by or merged
with another company, or we sell, liquidate, or transfer all or a portion of our assets.
● Partners.We may share your Personal Data with third parties with whom we partner,
including parties with whom we co-sponsor events or promotions, with whom we jointly offer
products or services, or to carry out other related activities that allow our Services to interact
with services our partners provide.
● Professional Advisors.We may share your Personal Data with professional advisors, such as
lawyers, auditors, bankers and insurers, where necessary in the course of the professional
services that they render to us.
● Vendors and Service Providers.We may share your Personal Data with third parties that
provide services on our behalf or help us operate the Services or our business, such as
hosting, information technology, customer support, email delivery, marketing, research and
analytics.
● Third Parties Designated by You.We also may disclose your Personal Data with third parties
where you have instructed us or provided your consent to do so.
INTERNATIONAL DATA TRANSFERS
Your information, including the Personal Data that you provide to us, may be transferred to, stored at
and processed by us outside the country in which you reside, including, but not limited to the United
States, where data protection and privacy regulations may not offer the same level of protection as
in other parts of the world. By providing any information, including Personal Data, on our Site, you
consent to such transfer, storage, and processing. We may also transfer Personal Data from the
European Economic Area or the United Kingdom to the United States, as needed, to perform the
Services that you have requested from us. We will take steps that we believe to be reasonably
necessary to treat your Personal Data securely and in accordance with this Policy.
SECURITY
We employ organizational, technical, and administrative measures designed to protect Personal
Data within our organization. However, as no electronic transmission or storage of Personal Data
can be entirely secure, we can make no guarantees as to the security or privacy of your Personal
Data. If you have reason to believe that your interaction with us is no longer secure, please
immediately notify us of the problem by contacting us via the “Contact Information” section below.
RETENTION
We will only retain your Personal Data as long as reasonably required for the purposes for which we
collected it. In the context of customer support, we retain information sufficient to connect
subsequent requests from the same user in order to provide efficient service, unless a longer
retention period is required or permitted by law (for example for regulatory purposes).
THIRD-PARTIES
Our Services may contain links or API connections to other websites, products, or services that we
do not own or operate. We are not responsible for the privacy and advertising practices of these third
parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party
API providers or any Personal Data you disclose to these third parties. We encourage you to read
their privacy policies before providing any Personal Data to them.
DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online sites that
you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not
Track,” please visitwww.allaboutdnt.com
YOUR RIGHTS AND CHOICES
In this section, we describe the rights and choices available to all users. Users who are located in
certain U.S. states, and Europe can find additional information about their rights below.
Opt-out of Marketing Communications.You may opt-out of marketing-related emails by following
the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note
that if you choose to opt-out of marketing-related emails, you may continue to receive service-related
and other non-marketing emails.
Advertising choices.You may be able to limit use of your Personal Data for interest-based
advertising through the following settings/options/tools:
● Browser settings.Changing your internet web browser settings to block third-party cookies.
● Privacy browsers/plug-ins.Using privacy browsers and/or ad-blocking browser plug-ins that
let you block tracking technologies.
● Platform settings.Certain platforms offer opt-out features that let you opt-out of use of your
information for interest-based advertising. For example, the following platforms provide
details about how users can exercise their choice to opt-out of interest-based advertising as
follows:
o Google:https://adssettings.google.com
o Meta:https://www.facebook.com/help/769828729705201?ref=cookies
o TikTok:https://www.tiktok.com/privacy/ads-and-your-data/en
o X:https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads
● Ad industry tools.Opting out of interest-based ads from companies that participate in the
following industry opt-out programs:
o Network Advertising
Initiative:http://www.networkadvertising.org/managing/opt_out.asp
o Digital Advertising Alliance:optout.aboutads.info.
o AppChoices mobile app, available athttps://www.youradchoices.com/appchoices,
which will allow you to opt-out of interest-based ads in mobile apps served by
participating members of the Digital Advertising Alliance.
● Mobile settings.Using your mobile device settings to limit use of the advertising ID
associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to
limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-
out programs described above.
Declining to provide information.We need to collect Personal Data to provide certain services. If you
do not provide the information we identify as required or mandatory, we may not be able to provide
those services.
CONTACT INFORMATION
We welcome your comments or questions regarding our privacy practices. If you have questions
about your privacy related to the Services or this Privacy Policy, you may contact us at:
Mail:
Exodus Movement, Inc.15418 Weir Street,No. 333
Omaha,NE68137
Email:
CHANGES TO THIS PRIVACY POLICY
We will post any updates to the Privacy Policy on this page, and the revised version will be effective
when it is posted. If we materially change the ways in which we process Personal Data previously
collected from you through our Services, we will notify you by email or other means.
STATE PRIVACY RIGHTS NOTICE
Except as otherwise provided, this section applies to residents of California, Colorado, Connecticut,
Utah, Virginia and other states to the extent they have privacy laws applicable to us that grant their
residents the rights described below (collectively, the“State Privacy Laws”)
This section describes how we collect, use, and share Personal Information (defined below) of
residents of these states and the rights these users may have with respect to their Personal
Information. Please note that not all rights listed below may be afforded to all users and that if you
are not a resident of one of these states listed above, you may not be able to exercise these rights. In
addition,we may not be able to process your request if you do not provide us with sufficient detail
to allow us to confirm your identity or understand and respond to it.
For the purposes of this Section,Personal Informationhas the meaning given to “personal data”,
“personal information” or other similar terms, and “Sensitive Personal Information” has the meaning
given to “sensitive personal information,” “sensitive data”, or other similar terms in the State Privacy
Laws, except that in neither case does such term include information exempted from the scope of
the State Privacy Laws. In some cases, we may provide a different privacy notice to certain
categories of residents of these states, such as job applicants, in which case that notice will apply
instead of this section.
Personal Information does not include information that is:
● Lawfully made available from government records.
● Deidentified or aggregated.
● Otherwise excluded from the scope of the State Privacy Laws.
YOUR STATE LAW PRIVACY RIGHTS
State Privacy Laws may provide residents with some or all of the following rights. However, these
rights are not absolute, and some State Privacy Laws do not provide these rights to their residents.
Therefore, we may decline your request in certain cases as permitted by law.
Right to Know and Access.You may submit a verifiable request for information about how we have
collected and use your Personal Information during the past 12 months: (i) categories of Personal
Information collected; (ii) business or commercial purposes for which categories of Personal
Information are collected or sold by us; (iii) categories of sources from which we collect Personal
Information; (iv) categories of third parties with whom we share Personal Information; (v) the
categories of Personal Information disclosed or sold for a business purpose; and (vi) of the
categories of third parties to whom the Personal Information was disclosed or sold for a business
purpose. You can also request a copy of the Personal Information that we have collected about you.
Right to Appeal.You can appeal our denial of any request validly submitted.
Right to Correction.You can ask us to correct inaccurate Personal Information that we have
collected about you.
Right to Deletion.Subject to certain exceptions, you may submit a verifiable request that we delete
Personal Information about you that we have collected from you.
Right to Opt-Out.In some circumstances, you may have opt-out rights with respect to your Personal
Information:
● Opt-out of certain processing for targeted advertising purposes.You can opt-out of certain
processing of personal information for targeted advertising purposes.
● Opt-out of profiling/automated decision making.You can opt-out of automated processing
or profiling performed on personal information to evaluate, analyze, or predict personal
aspects related to a person’s economic situation, health, personal preferences, interests,
reliability, behavior, location, or movements.
● Opt-out of other sales of personal data.You can opt-out of other sales of your Personal
Information.
Nondiscrimination.You have the right not to receive discriminatory treatment for the exercise of
your privacy rights, subject to certain limitations.
Consumers under 16.We do not have actual knowledge that we sell or share the personal
information of consumers under 16 years of age.
Sensitive Personal Information.We do not process Sensitive Personal Information for the purpose
of inferring characteristics about consumers under the California Consumer Privacy Act (“CCPA”).
Shine the Light.We do not rent, sell, or share Personal Information with non-affiliated companies for
their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code §
1798.83), unless we have your permission.
Submit Requests to Exercise Your Right to Know/Access, Appeal, Correction, or Deletion.To submit
requests to exercise your right to know/access, appeal, correction, or deletion, please email us via
our Contact Information section.
Submit Requests to Exercise Your Right to Opt-out of the “Sale” or “Sharing” of Your Personal
Information.While we do not sell Personal Information for money, like many companies, we use
services that help deliver interest-based ads to you as described above. The State Privacy Laws may
classify our use of some of these services as “selling” or “sharing” your Personal Information with
the advertising partners that provide the services. You can by submit requests to opt-out of tracking
for targeted advertising purposes or other sales of Personal Information by emailing us via the
Contact Information section.
Verification of Identity; Authorizing an Agent.We may need to verify your identity to process your
know/access, appeal, correction, or deletion requests and we reserve the right to confirm your
residency. To verify your identity, we may require government identification, a declaration under
penalty of perjury, or other information, where permitted by law.
Under some State Privacy Laws, you many enable an authorized agent to make a request on your
behalf. However, we may need to verify your authorized agent’s identity and authority to act on your
behalf. To authorize an agent to make a rights request on your behalf, please send us a written
authorization signed by you and the authorized agent to us via the Contact Information section. We
may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable
law.
Personal information that we collect, use and disclose.We have summarized the Personal
Information we collect and may disclose to third parties by reference below to both the categories
defined in the “Information We Collect” section of this Policy above and the categories of Personal
Information specified in the CCPA (Cal. Civ. Code §1798.140) and the below describes our practices
currently and during the 12 months preceding the effective date of this Privacy Policy. Information
you voluntarily provide to us, such as in free-form webforms, may contain other categories of
personal information not described below.
Personal Information
(“PI”) we collect
CCPA statutory
category
Categories of third
parties to whom we
“disclose” PI for a
business purpose
Categories of third
parties to whom we
“sell” or “share” PI
● Information You
Provide to Us
(Sites only)
● Identifiers
● Commercial
information
● California
customer
records
● Affiliates
● Advertising
partners
● Authorities and
others
● Business
transferees
● Partners
● Professional
advisors
● Vendors and
Service
providers
● Third parties
designated by
you
● Advertising
partners (to
facilitate
online
advertising)
● Information We
Collect
Automatically
(Sites only)
● Identifiers
● Online
Identifiers
● Commercial
information
● Affiliates
● Advertising
partners
● Authorities and
others
● Business
transferees
● Advertising
partners (to
facilitate
online
advertising)
Personal Information
(“PI”) we collect
CCPA statutory
category
Categories of third
parties to whom we
“disclose” PI for a
business purpose
Categories of third
parties to whom we
“sell” or “share” PI
● Internet or
Network
Information
● Partners
● Professional
advisors
● Vendors and
Service
providers
● Third parties
designated by
you
● Service
Interaction Data
(Blockchain
currency
management
software only)
● Identifiers
● Online
Identifiers
● Commercial
information
● Internet or
Network
Information
● Affiliates
● Third parties
designated by
you
● Professional
advisors
● Authorities and
others
● Business
transferees
● Advertising
partners (to
facilitate
online
advertising)
● Information We
Collect from
Other Sources
● Identifiers
● Online
Identifiers
● Commercial
information
● Internet or
Network
Information
● Affiliates
● Third parties
designated by
you
● Professional
advisors
● Authorities and
others
● Business
transferees
● Advertising
partners (to
facilitate
online
advertising)
NOTICE TO EUROPEAN USERS
GENERAL
Where this Notice to European users applies.The information provided in this “Notice to European
users” section applies only to individuals in the United Kingdom, Switzerland and the European
Economic Area (i.e.,“Europe”as defined at the top of this Privacy Policy).
Personal information.References to “Personal Information” in this Privacy Policy should be
understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information
about individuals from which they are either directly identified or can be identified.
Special Categories of Personal Data.References to “special categories of personal data” in this
European section of this Privacy Policy should be understood to mean special categories of
personal data as defined in the GDPR – i.e. personal information revealing racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union membership, and the processing
of genetic data, biometric data for the purposes of uniquely identifying a natural person, data
concerning health or data concerning a natural person’s sex life or sexual orientation.
Controller.Exodus is the controller in respect of the processing of your personal information covered
by this Privacy Policy for purposes of European data protection legislation (i.e., theEU GDPRand the
so-called‘UK GDPR’(as and where applicable, the“GDPR”and Swiss Federal Act on Data Protection
(“FADP”))). See the ‘Contact Information’ section above for our contact details.
OUR LEGAL BASES FOR PROCESSING
In respect of each of the purposes for which we use your personal information, the GDPR requires us
to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed
below.
● Where we need to perform a contract, we are about to enter into or have entered into with
you (“Contractual Necessity”).
● Where it is necessary for our legitimate interests and your interests and fundamental rights
do not override those interests (“Legitimate Interests”). More detail about the specific
legitimate interests pursued in respect of each Purpose we use your personal information for
is set out in the table below.
● Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
● Where we have your specific consent to carry out the processing for the Purpose in question
(“Consent”).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant
purposes for which we use your personal information – for more information on these Purposes and
the data types involved, see ‘How We Use The Personal Data We Collect’ above.
Purpose
Categories of personal
information involved
Legal basis
Service delivery,
analytics, and
operations (incl.
service
enhancement,
personalization, and
improvement)
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● Compliance with Law, if we are
legally obliged to respond to
your request.
● Consent, in respect to any
special categories of personal
data we may be processing or
optional cookies we may use.
● Legitimate Interest, in all other
cases – our legitimate interests
to develop, improve and
communicate about our
organization.
Marketing
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● Legitimate Interests. We have a
legitimate interest in promoting
our operations and goals as an
organisation and sending
marketing communications for
that purpose.
● Consent, in circumstances or in
jurisdictions where consent is
required under applicable data
protection laws to the sending
of any given marketing
communications.
To facilitate
connections and
engagements with
third-party services
or applications (incl.
third-party API
providers)
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● Legitimate Interests – we have
a legitimate interest in
promoting these promotions
and contests, including
associated publicising of our
business and operations.
● Consent – in circumstances or
in jurisdictions where consent is
required under applicable data
protection laws to the sending
of any given promotional
communications.
Purpose
Categories of personal
information involved
Legal basis
Compliance and
protection
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● Compliance with Law.
● Legitimate interest. Where
Compliance with Law is not
applicable, we and any relevant
third parties have a legitimate
interest in participating in,
supporting, and following legal
process and requests, including
through co-operation with
authorities. We and any relevant
third parties may also have a
legitimate interest of ensuring
the protection, maintenance,
and enforcement of our and
their rights, property, and/or
safety.
To create
pseudonymous,
aggregated, de-
identified and/or
anonymized data
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● Legitimate interest. We have
legitimate interest in
understanding what may be of
interest to our customers,
improving customer
relationships and experiences,
delivering relevant content to
our customers, measuring and
understanding the effectiveness
of the content we serve to our
customers.
Further uses
● Any and all data
types described in
the ‘Information We
Collect’ section
above as relevant in
the circumstances
● The original legal basis relied
upon, if the relevant further use
is compatible with the initial
purpose for which the Personal
Information was collected.
● Consent, if the relevant further
use is not compatible with the
initial purpose for which the
personal information was
collected.
RETENTION
We retain personal information for as long as necessary to fulfil the purposes for which we collected
it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to
establish or defend legal claims, or for Compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount,
nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use
or disclosure of your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and the applicable
legal requirements.
When we no longer require the personal information, we have collected about you, we will either
delete or anonymize it or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible. If we anonymize your personal information (so
that it can no longer be associated with you), we may use this information indefinitely without further
notice to you.
OTHER INFO
No Automated Decision-Making and Profiling.As part of the Services, we do not engage in
automated decision-making and/or profiling, which produces legal or similarly significant effects.
YOUR RIGHTS
General.European data protection laws give you certain rights regarding your personal information.
If you are located in Europe, you may ask us to take the following actions in relation to your personal
information that we hold:
● Access.Provide you with information about our processing of your personal information and
give you access to your personal information.
● Correct.Update or correct inaccuracies in your personal information.
● Delete.Delete your personal information where there is no good reason for us continuing to
process it - you also have the right to ask us to delete or remove your personal information
where you have exercised your right to object to processing (see below).
● Portability.Port a machine-readable copy of your personal information to you or a third party
of your choice.
● Restrict.Restrict the processing of your personal information, for example if you want us to
establish its accuracy or the reason for processing it.
● Object.Object to our processing of your personal information where we are relying on
Legitimate Interests – you also have the right to object where we are processing your
personal information for direct marketing purposes.
● Withdraw Consent.When we use your personal information based on your consent, you have
the right to withdraw that consent at any time.
postal address provided above. We may request specific information from you to help us confirm
your identity and process your request. Whether or not we are required to fulfill any request you
make will depend on a number of factors (e.g., why and how we are processing your personal
information), if we reject any request you may make (whether in whole or in part) we will let you
know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority.In addition to your rights outlined
above, if you are not satisfied with our response to a request you make, or how we process your
personal information, you can make a complaint to the data protection regulator in your habitual
place of residence.
● For users in the European Economic Area – the contact information for the data protection
regulator in your place of residence can be found
here:https://edpb.europa.eu/about-edpb/board/members_en
● For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website:https://ico.org.uk/make-a-complaint/
● For users in Switzerland – the contact information for the Swiss data protection regulator is
below:
Federal Data Protection and Information Commissioner
Feldeggweg 1
CH – 3003 Bern
Switzerland
Tel. +41 058 462 43 95
Website:https://www.edoeb.admin.ch/edoeb/en/home/meldeportale.html
DATA PROCESSING OUTSIDE EUROPE
We are a U.S.-based company and many of our service providers, advisers, partners or other
recipients of data are also based in the U.S. This means that, if you use the Service, your personal
information will necessarily be accessed and processed in the U.S. It may also be provided to
recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to
ensure a similar degree of protection is afforded to it by making sure one of the following
mechanisms is implemented:
You may contact us if you want further information on the specific mechanism used by us when
transferring your personal information out of Europe. You may have the right to receive a copy of the
appropriate safeguards under which your personal information is transferred by contacting us
