2. Information You Provide to Us
We collect Personal Data that you decide to share with us directly. At times, we may also require you to provide certain information to use certain parts of our Platform and Services, fulfill your requests, or provide you with certain services.
2.1 Account Information
As part of our onboarding process, when you create an account, you may provide us with your name, e-mail address and password. Any other information requested will be done so by our onboarding partner Onfido as part of our customer due diligence and enhanced due diligence processes and will be processed, retained and released in line Onfido Facial Recognition, Ts&Cs and Privacy policies.
2.2 Payment Information
2.3 Social Media Data
If you use social media logins to log in to our Platform and Services, we may access your public social media profile information. We also have pages on social media services such as Facebook, LinkedIn, Twitter etc. When you interact with our social media pages, we will collect Personal Data that you elect to provide to us, such as your contact details and messages sent. In addition, the companies that host our social media pages may provide us with aggregate information and analytics regarding the use of our social media pages.
2.4 Contacting Us
You may interact with us through our Platform and Services s, including through an online contact form, e-mail, surveys, social media, or any other communication mechanism. If you contact us directly, we may receive additional information about you such as your name, e-mail address, the contents of the message and/or attachments you may send us, and any other information you may choose to provide to us.
3. Information We Obtain from Others
4. Information We Automatically Collect
4.1 Log Information
We log usage data when you visit or otherwise use our Platform and Services, including our sites, app, and platform technology, such as when you view or click on content, perform a search, create content or perform a trade. We use logins, cookies, device information and internet protocol (“IP") addresses to identify you and log your use. As a blockchain based platform all transaction history is recorded, and these records are immutable and transparent.
4.2 Device and Location
When you visit or leave our Platform and Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or Internet Service Provider, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location, based on your phone settings.
4.3 Crash and Error Information
If the Platform and Services crash or return an error, we may collect data to determine the cause of the error using first- or third-party services. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.
5. Cookies and Other Technologies
5.1 What are Cookies and Other Technologies
A cookie is a small text file that can be stored on and accessed from your device when you visit our Platform and Services, to the extent you agree. Other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Platform and Services. This allows our Platform and Services to recognise your device from those of other users of our Platform and Services. The information provided below about cookies also applies to these other tracking technologies. You can find more useful information about cookies and other similar tracking technologies
at www.allaboutcookies.org and www.youronlinechoices.eu.
5.3 Third Party Cookies
Some Cookies and other Tracking Technologies that we use are from third party companies (third party cookies), such as Google, Microsoft, Reddit to provide us with web analytics and intelligence about our website which may also be used to provide measurement services and target ads. These companies use programming code to collect information about your interaction with our Platform and Services, such as the pages you visit, the links you click on and how long you are on our website. This code is only active while you are on the L3COS website.
For more information on how these companies collect and use information on our behalf, please refer to their privacy policies.
5.4 Cookies We Use
Depending on the Services, we may use the following types of cookies:
Necessary: Necessary cookies help make our Platform and Services usable by enabling basic functions like page navigation and access to secure areas of the Services. Our Platform and Services cannot function properly without these cookies. Disabling these cookies may make the Services in unavailable.
Preferences: Preference cookies are used by us to remember your settings and preferences and to improve your experience on our Platform and Services
Analytics: Analytics cookies help us collect information about your use of our Platform and Services and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor our Platform and Services’ performance, count page visits, spot technical errors, see how users reach our Platform and Services, and measure the effectiveness of marketing (including emails).
Marketing: Marketing cookies are used to show consumers display advertisements across websites, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns, both on our services and on other websites or mobile apps. Our third-party partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites.
5.5 Managing Cookies
If you do not want cookies to be dropped on your device, you can adjust the settings of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. For further information about how to do so, please see the specific browser procedures below, or see www.allaboutcookies.org. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access or use all, or parts or specific functionalities, of our Platform and Services.
If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Services from placing further cookies on your device, unless and until you adjust your Internet browser setting as described above.
You may opt out of behaviourally targeted ads anytime by clearing your cache of your browser's cookies. Additionally, you may opt-out of interest-based advertising from some third-party partners by visiting http://preferences-mgr.truste.com/,http://www.youronlinechoices.eu, or the third-party provider's websites. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.
6. How We Use Your Information
• To provide and maintain our Platform and Services
• For the performance of a contract such as the development, compliance, and undertaking
of the purchase contract for the services you have purchased or of any other contract
with us through our Platform and Services;
• To communicate with you by e-mail and other methods of communication to respond to
comments, questions, and other requests you send us;
• To contact you with special offers, promotions, and other information we believe will be
of interest to you;
• To provide the information, products, and services you request;
• For internal administrative and auditing purposes; To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities;
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform and Services, products, marketing, and your experience;
• To invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
• To enforce our policies or other agreements;
• To combine information collected through our Platform and Services and from other
sources so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information") such as de-identified demographic information, information about the device from which you accessed our Platform and Services, or other analyses we create;
• To use for any other purpose for which we provide notice at the time of collection; and
• To comply with legal obligations and legal process and to protect our rights, privacy,
safety, or property, and/or that of our affiliates, you, or other third parties.
7. How We Share and Disclose Information
7.1 Service Providers and Third Parties
7.2 Your Consent
We may share or disclose your Personal Data for other purposes pursuant to your consent or with your further direction.
7.3 Aggregate/De-Identified Data
From time to time, we may share Aggregate/De-Identified Information about use of our Platform and Services, such as by publishing a report on usage trends. The sharing and our other use of such data is unrestricted.
7.4 Legal Reasons
We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft, to protect the security of our Services, to enforce or apply our policies or other agreements, or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, at our discretion, that the requests are overbroad, vague, or lack proper authority.
7.5 Sale, Merger, or Other Business Transfer
As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third- party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
8. Your Choices
C. In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. We will tell you what Personal Data that you must provide in order to receive the Services.
D. Some browsers offer a "do not track" ("DNT") option. Since no common industry or legal standard for DNT has, to date, been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make commercially reasonable efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
9. European Residents
If you are a resident of the European Economic Area, Switzerland, or the United Kingdom (collectively, "Europe"), subject to any exemptions as provided by law, you may have certain rights regarding the Personal Data we, acting as the data controller, maintain about you. We offer you certain choices about what what Personal Data we collect from you, how we use that information, and how we communicate with you. If, at any time, you wish to exercise your rights, please reach out to us in accordance with the "Contact Us" Section below.
9.2 Right of Access
If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge you a reasonable fee.
9.3 Right to Rectification
If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
9.4 Right to Erasure
You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and there is no other legal basis for processing.
9.5 Right to Restrict Processing
You may ask us to restrict or 'block' the processing of your Personal Data in certain circumstances, such as if you contest its accuracy or object to us processing it.
9.6 Right to Data Portability
You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
9.7 Right to Object
You may ask us, at any time, to stop processing your Personal Data, and we will do so: (a) if we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Data for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt-out choices are respected in the future and to comply with data protection laws.
9.8 Right to Withdraw Consent
If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
9.9 Right to lodge a Complaint
If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.
We take reasonable precautions intended to help protect your Personal Data that we collect. Unfortunately, no system or online transmission of data is completely secure, and we cannot guarantee the security of data transmitted across the Internet. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
11. Information Retention
We retain your Personal Data as long as we are providing the Services to you or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you, and even if you close your account, we may retain your Personal Data in order to comply with our legal obligations and to allow for fraud monitoring, detection, and prevention activities. We also keep Personal Data to comply with our contractual commitments with the applicable financial exchanges, securities information processor, and other third party suppliers of information concerning financial markets. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
12. Data Processing and Data Transfers
To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside of your country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country. Personal Data collected within Europe may, for example, be transferred to and processed by third parties located in a country outside of Europe. In such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place.
13. Information Security
The security of your information is important to us. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect personal information we collect from unauthorized access, use, alteration, exfiltration, or destruction. Although we work hard to ensure the integrity and security of our systems, it must be recognised that no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorised use, or other factors may compromise the security of user information at any time.
14. Links to Third-Party Websites
The security of your information is important to us. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect personal information we collect from unauthorized access, use, alteration, exfiltration, or destruction. Although we work hard to ensure the integrity and security of our systems, it must be recognized that no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time.
15. Children's Privacy
Our Platform and Services are directed to individuals age 18 and over. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware of individuals who have provided us with Personal Data and are under the age of 18, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from Children which has been provided to us, please contact us in accordance with the "Contact Us" section below.
16. Contact Us