Effective Date: September 1, 2022
Last Updated: September 1, 2022
It is our policy to comply with all applicable privacy and data protection laws, including the California Consumer Privacy Act of 2018 (“CCPA”), the General Data Protection Regulation, Regulation (EU) No. 2016/279 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their data with us.
- Data Controller
- What Data We Collect About you
- Reason for Processing Your Personal Data
- How We Collect Your Personal Data
- How We Use Your Personal Data
- Disclosure of Your Personal Data
- Cookies and Automatic Data Collection Technologies
- Third-Party Links
- Your Rights and Choices
- International Transfers
- Data Security
- Contact Us
1. Data Controller
2. What Data We Collect About You
Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymized data), which we can use for any purpose. Some jurisdictions may consider your Internet Protocol (IP) address to be personal data. We may collect different kinds of personal data about you which we have grouped together as follows:
Information You Provide Us:
- Personal Identification Data includes your first name and last name, email address, your billing address, your home country, identity access management (IAM) key, staking key address, Internet Protocol (IP) address or similar identifiers.
- Transaction Data includes your payment and transaction information such as your credit/debit card number, your first and last name, and billing address.
- Communication Data includes your feedback that you communicate to us via email.
- Marketing Data includes names, mailing addresses, and email addresses.
Information Automatically Collected by Technology:
In addition, to the information you provide us, we may collect automatically collect certain information about your equipment, software, and browser to provide you with an efficient and personalized experience. This information includes:
- Device Data include the device’s hardware information, operating system, platform information, browser type, language information, and browser plugin types.
- Usage Data includes information about how you use our website and our Services.
Information Collected from Third Parties:
We may collect personal or anonymized information about you from third-party companies that provide products and services that are used in together with our website or our Services. For example, we may collect publicly available blockchain data linked to your crypto node clusters.
We do not collect any special categories of sensitive personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and precise geolocation data). Nor do we collect any information about criminal convictions and offenses.
3. Reason for Processing Your Personal Data
We may process the personal data you provide for the following reasons and legal bases:
|Why we process your data||Legal basis for processing|
|To set up your BloqCloud account.||To perform a contract with you or to enter into a contract with you.|
|To set up a prepaid subscription term to activate a node cluster.||To perform a contract with you or to enter into a contract with you.|
|To set up your staking node(s).||To perform a contract with you.|
|To receive your feedback that you provide us on our Contact Us page.||Legitimate interest in managing our website.|
|To respond to your requests and inquiries for technical support and general questions.||Legitimate interest in managing our website.|
|To engage in marketing with its customers.||Our legitimate interest based upon balancing your rights and freedoms against our interest in engaging in marketing.|
|To communicate with you about your comments regarding our website and Services you provide on third-party social media platforms.||Legitimate interest in managing our website.|
|To receive your comments on our social media accounts.||Legitimate interest in managing our website.|
|To allow you to exercise your data privacy rights.||Necessary to comply with our legal obligation.|
In addition, we may process your personal data for the following reasons:
- To carry out our obligations and enforce our rights.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use information that is not personal data for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on our website.
4. How we collect your personal data
We use different methods to collect information from and about you including through:
- Direct interactions. You may give us information about you by interacting with our website, by communicating with us via email, third-party collaboration platforms, or contact us page. This includes information you provide by emailing us about our website or Services or leaving feedback on our contact us form.
- Third-party or publicly available sources. We may receive information about you from third parties. The information we receive includes analytics information for improvement of our website and Services.
- Technical and Communication Data from the following parties: We may collect information from third-parties providers such as Twitter, Facebook, GitHub, Google Analytics, and LinkedIn Insights. The information we may collect includes your feedback about our Services on our Twitter account, GitHub page, Slack account, Telegram, and LinkedIn.
5. How We Use Your Personal Data
The Company may use your personal data to:
- Communicate with you. This may include: (i) informing you of our new services and promotional activities that may be of interest to you; (ii) providing information about our Services; (iii) responding to your feedback about our website and Services, including, for example, technical support and service improvements to our website and Services; (iii) responding to your questions or inquiries, including technical questions and troubleshooting using our Services; (iv) responding to your general inquiries; (v) responding to your inquiries for a demo request; (vi) responding to your privacy inquiries; and (vii) inviting you to participate in market research surveys.
- Develop and manage our relationships with you and our business partners. This may include: (i) delivering services or carrying out transactions you or our business partners have requested; (ii) providing information about our Services and advertisements, that may be of interest to you; (iii) providing you with a more consistent experience in interacting with us, including by learning more about you and how you use and interact with our website and Services; and (iv) planning, managing, and performing our contractual relationships with our business partners.
- Improve our website and Services. This may include: (i) customizing our website to your preferences or interests, (ii) making them more compatible with your devices and browsers, or otherwise making our website and Services easier to use; (iii) maintaining the security of our website and Services and otherwise protecting them; and (iv) improving our website and Services; and (v) developing new services and platforms.
- Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting, preventing, fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuse of our website or Services; and (v) protecting our rights or property, or yours or other health, safety, welfare, rights, or property.
We may also use your personal data for other uses consistent with the context in which the data was collected or with your consent or lawful purposes. If we believe the purpose for which we use your personal data for other purposes goes beyond the scope of your consent you provide during the personal data collection, we will communicate with you to obtain your consent.
We may anonymize or aggregate any of the data we collect and use it for any purpose, including research and product development. Such anonymized or aggregated data will not identify you individually.
6. Disclosure of Your Personal Data
- We may also disclose your personal data with third-party processors to perform support Services and to assist us in processing your personal data as described above. These processors are required to treat your personal data in compliance with all applicable privacy and data protection laws.
- We may share your personal data to third parties when we have a good faith belief that disclosure is necessary:
- (i) to comply with a law, regulation, court order, or other legal processes;
- (ii) to detect, prevent, and respond to fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuse of our website or Services;
- (iii) to protect our rights or property or yours or others’ health, safety, welfare, rights, or property; or
- (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
- We may disclose your personal data with third parties in connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Bloq, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
- We may share your data with your consent or at your request.
- We may share anonymized or Aggregated Data internally and with third parties for any purpose. Such information will not identify you individually.
7. Cookies and Automatic Data Collection Technologies
Our website may use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized experience when you browse our website. It also allows us to improve our website by enabling us to:
- Estimate our audience size and usage patterns.
- Store your preferences, so we may customize our website according to your individual interests.
- Recognize you when you return to our website.
The technologies we use for this automatic data collection may include:
- Web Beacons, Pixel Tags, Clear Gifs. Our website pages and emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your Rights and Choices.
Most web browsers include a Do-Not-Track (“DNT”) signal or similar mechanisms for your privacy preference. At this time, there is no technology standard for recognizing and implementing DNT signals has been finalized. Given the state of technology, we do not respond to DNT signals or any other mechanism that automatically communicates your preference not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
8. Third-Party Links
Some content or applications on our website may be served by third parties, content providers and application providers including the following:
- Third-party links. Our website may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms, and we encourage you to read those terms before interacting with third-party sites.
For the categories of data that we collect the following table shows the maximum retention period for the information.
|Data Category||Maximum Retention Period|
|Personal Identification Data||Your personal identification data will be retained for five (5) years after terminating your account.|
|Transaction Data||Your Transaction data provided through our website will be retained for five (5) years after terminating your account.|
|Marketing Data||Marketing data that you provide will be retained for no longer than two (2) years.|
|Device and Usage Data||Your device and usage data will be retained for no longer than two (2) years.|
Our website and Services are not intended for children under 16 years of age. We will not knowingly solicit or collect personal data from children under 16, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 16 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.
11. Your Rights and Choices
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.
- Accessing, Updating, and Deleting Your Information. You can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of personal data that you have provided to us. We may also ask you to verify your identity before we respond to your request. Depending on your request, we may not accommodate your request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
- California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your personal data. Please see Your California Privacy Rights for more information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. At this time, we do not engage in this type of disclosure.
- EU Residents. If you are a resident of the European Union, you have the right to:
- request access to your personal data, commonly known as a “data subject access request,” which allows you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.
- We may make automated decisions about you based on your personal data that may affect your access or Services provided to you. You have the right not to be subject the automated decision making so long as the decision is not necessary for the performance of the contract with you or required by legal obligation. If the decision making is necessary, you may contest the decision and request human intervention in the decision-making process.
- You also have a right to lodge a complaint with the data protection authority where you live.
12. International Transfers
If you are located in the EEA, we have put in place appropriate measures to comply with the laws and regulations to ensure that the transfer of personal data to countries outside of the EEA provides an adequate level of data protection.
13. Data Security
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your personal data for as long as reasonably necessary to fulfill the purpose of collecting it.
We also require our service providers and business partners to whom we disclose the information to do the same. When you use certain types of information, for example, when you provide us with your credit card or debit card information on our website, we will encrypt the transmission of that information using secure socket layer technology (SSL). We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.