TheDatafi - On-chain Data Institutional Analyst (collectively, “TheDatafi”)

TheDatafi - Tổ chức Phân tích On-chain data (gọi chung là “TheDatafi”)

TheDatafi - On-chain Data Institutional Analyst

1. TheDatafi Privacy Policy

Date of Last Update: Jan 1, 2023.

TheDatafi - On-chain Data Institutional Analyst, Inc. and its affiliates (collectively, “TheDatafi ”) are committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”), together with our Terms of Use (“Terms”) governs our collection, processing and use of your personal data. By accessing the Website, you confirm that you have read this Privacy Policy and consent to the information collection and specific purposes described herein. Capitalized terms not defined herein have the meaning used in the Terms.

2. Our Relationship with You

TheDatafi has the following relationships with individuals on its Services:

“Users'' are individuals providing personal information to us via our website, pages, social media accounts, or other means. For example, Users can sign up to be added to the public Lists, receive marketing communications or newsletters, or interact with us on our social media accounts. TheDatafi is in a “data controller” relationship with Users.
“Customers” are individuals that have purchased or obtained the TheDatafi Services. Here, TheDatafi is in a “data controller” relationship with Customers.

Hereinafter, we may refer to Users and Customers collectively as “you.”

3. Changes to This Privacy Policy

We may amend this Policy at any time by posting the most current version on our website. If we make any material changes to your rights under this Policy, we will notify you by means of a prominent notice in advance of such changes coming into effect. A prominent notice may include sending email notifications to the email address we have on file, or providing you with an in-application notice such as a banner or pop-up alerting you of the changes. We will update the “Last Modified” date at the top of the Policy when we post the new Policy. Your continued use of the Services after posting of the Policy will constitute your acceptance of the changes.

In addition, we may provide you with "just-in-time" disclosures or additional information about our data collection, purposes for processing, or other relevant information. The purpose of such just-in-time notices is to supplement or clarify our privacy practices or provide you with additional choices about how we process your personal information.

4. What Information is Collected?

When you use our Services, we collect personal information about your use of our Services and information that you send us. We may also obtain information about you from third party sources.

Throughout this Policy, we use the term "personal information" to describe information that identifies you or makes you identifiable. We do not consider personal information to include information that has been anonymized so that it does not identify a specific individual.

We may collect personal information in the following ways:

● Information you give us. We may collect information that you provide to us, such as when you create a TheDatafi Account, make a comment on our blog, or when you otherwise correspond with us regarding our Services (e.g., inquiry to customer support team, social media, etc.)

● Cookies. We use technologies like cookies, web beacons and pixel tags to gather information about how you are interacting with the Services, which may include identifying your IP address, browser type, and referring page. Please see more information about how we use Cookies below.

● Contact Information. To engage in cryptocurrency transactions via email, to interact with others via our Services, or to invite others to sign up for TheDatafi via our referral program, you may share other individuals’ contact information with us.

● Account Registration. To create an account on TheDatafi , you must provide us with your first name, last name, and email address.

● Transaction Information. When you engage in transactions via our Services, we collect transaction-related information such as amount sent, date, and information about the payment instrument used to complete your transaction (e.g. cryptocurrency public address or credit card).

● Performance and Log Data. Our servers automatically record information created by your use of our Services, which may include information such as, but not limited to, your IP address, browser type, operating system, command line information, diagnostic information related to the Services (i.e., crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms.

Parts of our Services are public, such as parts of our Lists and social media accounts, and any information that is disclosed on such public parts of our Services may appear on search engines or other publicly available platforms, and may be “crawled,” searched and used by third parties or other Users and Customers of the Services. Please do not post any information that you do not want to reveal publicly.

5. How is Collected Information Used?

Generally, we collect and use information from you to provide, protect, and improve our Services, and to provide you with a personalized experience when using our Services. For example, when you provide TheDatafi with your email address, we may send you updates on new or expanded Services, notices about security updates or change to our policies, and other administrative or transactional information. Much of the information you provide us through our Services is information that is designed to be made public, such as your TheDatafi Account information.

Some specific examples of how TheDatafi may use your personal information include:

1. To provide you with the Services. We process your personal information when you sign up for and use our Services (including the Lists and Tasks), make transactions, or participate in our referral program. When you sign up for an TheDatafi account, we let you choose which Services you would like to enable. When you enable a new part of the Services, we will disclose how we handle your personal information and ask for any necessary permissions to provide the Services to you. When you enable new Services, you may allow us to collect additional personal information about you or others as necessary to provide the Services. We share your personal information with our service providers and partners to the extent necessary to provide you with the Services. We cannot provide you with the Services without such information.

2. To provide you with administrative communications. We will contact you to keep you updated about your account and the Services, such as changes to this Privacy Policy, our Terms of Use and our other policies, security updates, or to provide transaction-related information to you. Without such communications, we cannot provide you with important information about your continued use of our Services.

3. For security purposes. We process your personal information to enhance the security of our Services and to combat spam, malware or other security risks. Our processing includes monitoring your activities on our Services and verifying your identity and access to the Services. Without processing your personal information, we may not be able to ensure the security of our Services.

4. To provide customer service. When you contact us with questions, concerns, disputes, feedback or any other reason, we process your personal information to respond to you. Without your personal information, we cannot respond to you or ensure your continued enjoyment of our Services.

5. To enforce our terms, agreements and policies. We process your personal information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services or violations of our terms and agreements with you. In addition, we may process your personal information to enforce our agreements with third parties and partners, and/or collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.

Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), TheDatafi processes the personal information of Users and Customers located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on its contract with such individuals.

1. To maintain legal and regulatory compliance, and to prevent fraud. We process your personal information to comply with sanctions laws, tax law, or as otherwise necessary to fulfill our other business obligations; identify, prevent, and mitigate fraud on our Services; and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.

Designated Countries: Pursuant to the Data Protection Laws, TheDatafi processes the personal information of Users and Customers located in the Designated Countries to comply with its legal obligations.1. Designated Countries: For Users and Customers located in the Designated Countries, please see “Marketing Activities” under Section 12 below for more information.

2. To engage in marketing and promotional activities. TheDatafi may send you marketing communications to alert you about new products or services. You can opt-out of our marketing activities at any time. When you share your friends’ contact information with us, we may reach out to them to invite them to use our Services and to continue receiving our communications. However, you are responsible for determining whether the individuals you invite on our Services would like to receive such communications from you – TheDatafi does not require you to provide such information to continue enjoying our Services. Please note, transactional communications about your account or our Services are not considered “marketing” communications.

3. Designated Countries: For Users and Customers located in the Designated Countries, please see “Marketing Activities” under Section 12 below for more information.

4. To conduct research and development. In order to offer you new, customized or improved features on our Services, we process your personal information for research and development purposes. Your personal information helps us better understand the way you use and interact with our Services. Without such processing, we cannot ensure your continued enjoyment of part or all of our Services.

5. To enhance your experience on the Services. We process your personal information to provide you with a unique and personalized experience on our Services. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

6. Use of Cookies

Cookies are small text files that are sent to your computer to ensure the technical functionality of the website. TheDatafi uses cookies in some areas of this Website to make it easier for you to use the pages and to make them more personalized.

Where required by the law, we will use cookies only if you have given your consent.

Retention of Personal Data

We will hold your personal data only for as long as it is necessary for us to do so in order to achieve the purposes described in this Privacy Policy and our own legal and regulatory requirements. From time to time, we perform analysis concerning the use of our Website using personal data.

Please be aware that public blockchains provide transparency into transactions and TheDatafi is not responsible for preventing or managing information broadcasted on a blockchain.

Security, Protection and Use of Personal Data

TheDatafi implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

the pseudonymization and encryption of personal data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Recipients of Personal Data

TheDatafi may make available the personal data that you provide to us to our affiliates and related entities, agents, representatives, service providers and contractors for the purposes outlined in this Policy. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers that we engage with are restricted to only using the information according to our instructions.

We also reserve the right to disclose personal data that we believe, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect security or integrity of TheDatafi and to protect the rights, property or safety of TheDatafi , our users or others.

Data Subjects’ Rights

The user has the right to obtain confirmation as to whether or not personal data concerning him or her are being collected, processed, used, or disclosed. Where that is the case, the user has the right to access the personal data and all relevant information, as well as to request deletion of the personal data. Furthermore, users have the right not to receive discriminatory treatment for exercising these rights.

According to the Website’s Terms of Use, users must be at least eighteen years of age, of sound mental capacity and possess all technical knowledge necessary or advisable to understand and evaluate the risks of the Website. TheDatafi does not knowingly collect or store any personal information about users under 18. If you believe such information has been inadvertently processed, we will take necessary steps to remove such information from our database.

Updates

Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of TheDatafi . If we change this Privacy Policy, we will take steps to notify all users by email or by a notice on our Website, and will publish the amended Privacy Policy on the Website.

Contact

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices, please contact us at info@thedatafi.com.

7. Designated Countries Privacy Rights

This Section only applies to Users and Customers of the Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in. Where we rely only on your IP address, we cannot apply the terms of this Section to any User or Customer that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this Section conflict with other terms contained in this Policy, the terms in this Section shall apply to Users and Customers in the Designated Countries.1. Our Relationship to You. TheDatafi is a data controller with regard to any personal information collected from Customers or Users of its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.
Lawful Basis for Processing Your Personal Information. We describe our lawful basis for processing in Section 6 (“How Is Collected Information Used”) and Section 7 (“Information We Share”) under headings entitled “Designated Countries.” The lawful bases on which we rely to process your personal information include: your consent to the processing; satisfaction of our legal obligations; to protect your vital interests; to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; in the public interest; or for our legitimate interests as described in those sections.
Marketing Activities. Direct marketing includes any communications we send to you that are only based on advertising or promoting products and services. Transactional communications about your account or our Services are not considered “direct marketing” communications. We will only contact Users or Customers by electronic means (including email or SMS) based on our legitimate interest or their consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.
If you do not want us to use your personal information in this way, please click the unsubscribe link in your emails, or contact us at info@TheDatafi .io. You can object to direct marketing at any time and free of charge.
Individual Rights. We provide you with the rights described below when you use our Services. Please contact us at info@TheDatafi .io. if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity.
Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways: (i) where denial of access is required or authorized by law; (ii) when granting access would have a negative impact on other's privacy; (iii) to protect our rights and properties; and (iv) where the request is frivolous or burdensome.
Right to withdraw consent. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.
Right to erasure (the “Right to be Forgotten”). You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:
1. You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information.
2. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
3. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defend legal claims.
4. You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
5. We will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
Notification to third-parties. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
Right to Lodge a Complaint. If you believe we have infringed or violated your privacy rights, please contact us at info@TheDatafi .io so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

8. Contact Us

If you have questions or concerns regarding this Policy or would like to access, change or delete your personal information, or have a complaint, please contact us on our support page or by emailing us at info@thedafi.com