WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us. Information we collect from you may include:
- Identity information, such as your first name, last name, username or similar identifier, title, date of birth and gender.
- Contact information, such as your postal address, email address and telephone number.
- Profile information, such as your username and password, interests, preferences, feedback and survey responses.
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us.
- Financial information, such as your credit card or other payment card details.
- Transaction information, such as details about purchases you make through the Service and billing details.
- Usage information, such as information about how you use the Service and interact with us.
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.
- Financial information, such as bank account number and bank routing number; financial assets holdings.
- Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions.
Information collected by Infura when you use Infura as your default RPC provider in EZ Wallet. https://www.ezwallet.xyz/ (“EZ Wallet”) and https://infura.io/ (“Infura”) are both products offered by the Company and Infura is the default Remote Procedure Call (RPC) provider in EZ Wallet. When you use Infura as your default RPC provider in EZ Wallet, Infura will collect your IP address and your Ethereum wallet address when you send a transaction. However, if you’re using your own Ethereum node or a third party RPC provider with EZ Wallet, then neither Infura nor EZ Wallet will collect your IP address or Ethereum wallet address (but you should be aware your information will be subject to whatever information collection performed by the RPC provider you are using and their terms regarding such collection).
Information Automatically Collected. We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
We also may use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://www.google.com/analytics/terms/us.html. Please note that EZ Wallet does not use Google Analytics in its wallet.
We also use Mixpanel in some of our Services in order to better understand how you are using the Sites. You can find more information about Mixpanel’s use of your personal data here: https://mixpanel.com/legal/privacy-policy/.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.
Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
USE OF PERSONAL INFORMATION
To provide our service
We will use your personal information in the following ways:
- To enable you to access and use the Services.
- To provide and deliver products and services that you may request.
- To process and complete transactions, and send you related information, including purchase confirmations and invoices.
- To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (AML) laws and know-your-customer (KYC) requirements), lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
SHARING OF PERSONAL INFORMATION
- Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes.
- We may share information to comply with laws, including KYC and AML requirements.
- We may share information to respond to lawful requests and legal processes.
- We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- Professional Advisors and Service Providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as bill and credit card payment processing, customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
- Other. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.
Note: We may also share aggregated and/or anonymized data with others for their own uses.
The Company has offices outside of the EU and has affiliates and service providers in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
EU users should read the important information provided below about transfer of personal information outside of the European Economic Area (EEA).
HOW INFORMATION IS SECURED
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Sites and subsequently we will delete that information.
MARKETING COMMUNICATIONS AND SHARING
You may instruct us not to use your contact information to contact you regarding services, promotions, surveys and special events that might appeal to your interests by contacting us using the information below. You can also opt-out by following the instructions located at the bottom of any commercial emails messages you may receive.
Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you, such as service-related announcements (e.g., if our Services are temporarily suspended for maintenance).
Or, if you have downloaded our mobile application and enabled push notifications on your mobile device, we may send you alerts and notifications through push notifications, for example, to communicate status updates on our Services. However, you may choose to disable these notifications (except for the initial notification intended to verify your identity).
THIRD PARTY LINKS AND WEBSITES
This Privacy Notice does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which our Sites link. The inclusion of a link on our Sites does not imply that we or our affiliates endorse the practices of the linked website.
In the event that our Sites link to other websites that include our branding, this Privacy Notice does not apply to those other websites. Visitors to those websites are advised to carefully read the notices on those individual websites.
We welcome your comments or questions about this Policy, and you may contact us at:
NOTICE TO EU DATA SUBJECTS
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
Use for New Purposes
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
- 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.
- Transfer. Transfer 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.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.