Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Information You Provide Us.
We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, Ethereum address when you contact us or make a purchase from our website.
If you use our Services on your mobile device, we may collect your phone number and the unique device id number.
Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, Ethereum address, and other requested information if you contact us via e-mail regarding support for the Services.
We may also collect Personal Data at other points in our Service that state that PersonalData is being collected.
Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Information Collected by Our Servers. To make our Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, Ethereum address, wallet type, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyse trends, administer the Service, track users' movements around the Service, gather demographic information about our user base as a whole, and better tailor our Services to our users' needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user's computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users' Personal Data.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labelled website or companies that offer their products and/or services on our Service. In particular, MetaMask and other wallets provide us with your Ethereum address and certain other information you choose to share with MetaMask and other wallets. These third-party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Service in order to improve it. We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us.
Use of Your Personal Data
General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better.
We use your Personal Data in the following ways:
provide improved administration of our Service; provide the Services you request, including but not limited to facilitating your cryptocurrency transactions through MetaMask (https://metamask.io) or other wallets; improve the quality of experience when you interact with our Service; send you administrative e-mail notifications, such as security or support and maintenance advisories; send you e-mail notifications related to actions on Service; make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; in any other way we may describe when you provide the Personal Data; and send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of PTCo. We may use your Personal Data to contact you about our own and third parties' goods and services that may be of interest to you.
Third Party Service Providers.
We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Service; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the PTCo.
As Legally Required.
We may also disclose your Personal Data, to fulfil the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent. We do not sell your Personal Data.
Third Party Websites.
Third-Party Wallet Extensions.
Your Choices Regarding Information.
You have several choices regarding the use of information on our Services:
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser's technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the address given in paragraph (1).
Data Access and Control.
You can view, access, edit, or delete your personal data for many aspects of the Service by contacting us. You can also make choices about PTCo.'s use of your data. You can always choose whether you want to receive marketing communications from us. You can also opt out from receiving marketing communications from us by using the opt-out link on the communication, or by visiting your account settings page. We may retain an archived copy of your records as required by law or for legitimate business purposes.
You can access your Personal Data by contacting us.
You can request a copy of your Personal Data by contacting us here and including “Please send me my Personal Data” in the subject line. PTCo. will verify your ability to access that email, then send you a digital export of the data we hold that is associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.
You can delete your Personal Data on your account settings page. Alternatively, you may request that PTCo. delete your personal data by contacting us here and including “Please delete my Personal Data” in the subject line. PTCo. will verify your ability to access that email, then delete the Personal Data associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.
You can modify your Personal Data on your account settings page.
We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our website. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
A Note About Children.
We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to PTCo. and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address indicated in Section 1 above.
A Note to Users Outside of the United States - especially UK and EU users.
How long will we store your information?
We will keep your information for up to 20 years, from your last interaction within the platform or until you request that your data be deleted. If we delete your data, it can take up to 6 months of to remove from our back up facility, simply due to the way that they operate, and in some cases, it may remain on our back up facility for legal and regulatory purposes.
Following the confirmed death of a user, their data will be removed after a period of 10 years.
How do we keep your information secure?
You access your information via secure password credentials, set by you. Information kept by us is stored within Amazon Web Solutions, a cloud-based service, situated in their London region, and is encrypted both at rest and in transit.
We have strict procedures and security measures to prevent, as much as reasonably possible, unauthorised access to, or disclosure of, your information. We cannot guarantee the security of any information you transmit to us, such as emails containing information about you.
What rights do you have regarding your information?
We are committed to complying with your rights to your information and will deal with any requests, outlined below without undue delay, and in line with regulatory timeframes. By law you have a number of rights that apply in certain circumstances. These include the right to
• Object to processing This means you may not want your information used in some ways
• Restrict processing This means we can no longer use your information, but we will store it and maintain your place on our data set of users whose information we hold but cannot use moving forward
• Be informed You should have clear, accessible and transparent information provided to you so you understand how we work, protect and use your information
• Have access to your information This enables you to check we are using your data correctly and is done by contacting us directly or your healthcare team.
• Data rectification If you see incorrect or incomplete information, you can ask to have that corrected.
• Be erased This means you can be “forgotten”. It is important to know; this is not a general statement and is subject to some conditions, but the right means you could have all the information we hold on you deleted where there is no compelling reason for us to keep using it
• Move your data This is referred to as portability. Your data should be provided for you in a way that is accessible and provides you with the option of reusing the data in other situations, as you own your data
• Complain You have the right to lodge a complaint, and we will respect this and deal with it in a timely fashion in line UK regulations.
• Withdraw consent This means you remove the right for us to use your data. You may do this at any point and without providing a reason for doing so. Removing your consent though means you will no longer be able to use our services.
Our Data Protection Officer is Roi Sagi.
If you would rather deal with an independent group or feel we have not satisfactorily dealt with your enquiry, you can contact the ICO by email firstname.lastname@example.org OR phone 0303 123 1113.
Full details of the Data protection regulation, can be found at www.gov.uk/data-protection.
Date of Publication: 26th March 2022