Version Date: February 19, 2019
GATHERING, USE AND DISCLOSURE OFNON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more,can be directly associated with a specific person. Like most website operators,Company gathers from users of the Website Non-Personally-IdentifyingInformation of the sort that Web browsers, depending on their settings, maymake available. That information includes the user’s Internet Protocol (IP)address, operating system, browser type and the locations of the websites theuser views right before arriving at, while navigating and immediately after leavingthe Website. Although such information is not Personally-IdentifyingInformation, it may be possible for Company to determine from an IP address auser’s Internet service provider and the geographic location of the visitor’spoint of connectivity as well as other statistical usage data. Company analyzes Non-Personally-IdentifyingInformation gathered from users of the Website to help Company betterunderstand how the Website is being used. By identifying patterns and trends inusage, Company is able to better design the Website to improve users’experiences, both in terms of content and ease of use. From time to time,Company may also release the Non-Personally-Identifying Information gatheredfrom Website users in the aggregate, such as by publishing a report on trendsin the usage of the Website.
A “Web Beacon” is an object that is embedded ina web page or email that is usually invisible to the user and allows websiteoperators to check whether a user has viewed a particular web page or an email.Company may use Web Beacons on the Website and in emails to count users whohave visited particular pages, viewed emails and to deliver co-brandedservices. Web Beacons are not used to access users’ Personally-IdentifyingInformation. They are a technique Company may use to compile aggregatedstatistics about Website usage. Web Beacons collect only a limited set ofinformation, including a Web Cookie number, time and date of a page or emailview and a description of the page or email on which the Web Beacon resides.You may not decline Web Beacons. However, they can be rendered ineffective bydeclining all Web Cookies or modifying your browser setting to notify you eachtime a Web Cookie is tendered, permitting you to accept or decline Web Cookieson an individual basis.
We may use third-party vendors, includingGoogle, who use first-party cookies (such as the Google Analytics cookie) andthird-party cookies (such as the DoubleClick cookie) together to inform,optimize and serve ads based on your past activity on the Website, includingGoogle Analytics for Display Advertising. The information collected may be usedto, among other things, analyze and track data, determine the popularity ofcertain content and better understand online activity. If you do not want anyinformation to be collected and used by Google Analytics, you can install anopt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/oropt out from Google Analytics for Display Advertising or the Google DisplayNetwork by using Google’s Ads Settings (www.google.com/settings/ads).
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-PersonallyIdentifying Information we collect under any of the above circumstances. We mayalso share it with third parties and our affiliate companies to develop anddeliver targeted advertising on the Website and on websites of third parties.We may combine Non-Personally Identifying Information we collect withadditional Non-Personally Identifying Information collected from other sources.We also may share aggregated information with third parties, including advisors,advertisers and investors, for the purpose of conducting general businessanalysis. For example, we may tell our advertisers the number of visitors tothe Website and the most popular features or services accessed. Thisinformation does not contain any Personally-Identifying Information and may beused to develop website content and services that we hope you and other userswill find of interest and to target content and advertising.
Mobile Device Additional Terms
•Mobile Device. If you use a mobiledevice to access the Website or download any of our applications, we maycollect device information (such as your mobile device ID, model andmanufacturer), operating system, version information and IP address.
•Geo-Location Information. Unlesswe have received your prior consent, we do not access or track anylocation-based information from your mobile device at any time whiledownloading or using our mobile application or our services, except that it maybe possible for Company to determine from an IP address the geographic locationof your point of connectivity, in which case we may gather and use such generallocation data.
•Push Notifications. Wesend you push notifications if you choose to receive them, letting you knowwhen someone has sent you a message or for other service-related matters. Ifyou wish to opt-out from receiving these types of communications, you may turnthem off in your device’s settings.
•Mobile Analytics. Weuse mobile analytics software to allow us to better understand thefunctionality of our mobile software on your phone. This software may recordinformation, such as how often you use the application, the events that occurwithin the application, aggregated usage, performance data and where theapplication was downloaded from. We do not link the information we store withinthe analytics software to any Personally-Identifying Information you submitwithin the mobile application.
We may provide you the option to connect your accounton the Website to your account on some social networking sites for the purposeof logging in, uploading information or enabling certain features on theWebsite. When logging in using your social network credentials, we may collectthe Personally-Identifying Information you have made publicly available on thesocial networking site, such as your name, profile picture, cover photo,username, gender, friends network, age range, locale, friend list and any otherinformation you have made public. Once connected, other users may also be ableto see information about your social network, such as the size of your networkand your friends, including common friends. By connecting your account on theWebsite to your account on any social networking site, you hereby consent tothe continuous release of information about you to us. We will not send any ofyour account information to the connected social networking site without firstdisclosing that to you. Each social network may further allow you to setprivacy controls around your information on their system, and our collection ofinformation will always follow such controls and permissions. This feature issubject to continuous change and improvement by us and each social networkingsite involved, and therefore the available features and shared information aresubject to change without notice to you.
We may use hyperlinks on the Website which willredirect you to a social network if you click on the respective link. However,when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s“tweet” button or the Google+, that particular social network’s plugin will beactivated and your browser will directly connect to that provider’s servers. Ifyou do not use these buttons, none of your data will be sent to the respectivesocial network’s plugin provider. So for example, when you click on theFacebook’s “Like” button on the Website, Facebook will receive your IP address,the browser version and screen resolution, and the operating system of thedevice you have used to access the Website. Settings regarding privacyprotection can be found on the websites of these social networks and are notwithin our control.
COLLECTION, USE AND DISCLOSURE OFPERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-IdentifyingInformation is information that can be directly associated with a specificperson. Company may collect a range of Personally-Identifying Information fromand about Website users. Much of the Personally-Identifying Information collectedby Company about users is information provided by users themselves when (1)registering for our service, (2) logging in with social network credentials,(3) participating in polls, contests, surveys or other features of our service,or responding to offers or advertisements, (4) communicating with us, (5)creating a public profile or (6) signing up to receive newsletters. Thatinformation may include each user’s name, address, email address and telephonenumber, and, if you transact business with us, financial information such asyour payment method (valid credit card number, type, expiration date or otherfinancial information). We also may request information about your interestsand activities, your gender, age, date of birth, username, hometown and otherdemographic or relevant information as determined by Company from time to time.Users of the Website are under no obligation to provide Company withPersonally-Identifying Information of any kind, with the caveat that a user’srefusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOUCONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION ASDESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYINGINFORMATION” SECTION.
We may occasionally use your name and emailaddress to send you notifications regarding new services offered by the Websitethat we think you may find valuable. We may also send you service-relatedannouncements from time to time through the general operation of the service.Generally, you may opt out of such emails at the time of registration orthrough your account settings, though we reserve the right to send you noticesabout your account, such as service announcements and administrative messages,even if you opt out of all voluntary email notifications.
Company will disclose Personally-IdentifyingInformation under the following circumstances:
• Marketing Communications. Unless users opt-out from receivingCompany marketing materials upon registration, Company may email users aboutproducts and services that Company believes may be of interest to them. If youwish to opt-out of receiving marketing materials from Company, you may do so byfollowing the unsubscribe link in the email communications, by going to youraccount settings (if applicable) or contacting us using the contact informationbelow.
•Third-Party Service Providers. We may share your Personally-IdentifyingInformation, which may include your name and contact information (includingemail address) with our authorized service providers that perform certainservices on our behalf. These services may include fulfilling orders, providingcustomer service and marketing assistance, performing business and salesanalysis, supporting the Website’s functionality and supporting contests,sweepstakes, surveys and other features offered through the Website. We mayalso share your name, contact information and credit card information with ourauthorized service providers who process credit card payments. These serviceproviders may have access to personal information needed to perform theirfunctions but are not permitted to share or use such information for any otherpurpose.
Changing Personally-Identifying Information;Account Termination
Company uses the Personally-IdentifyingInformation in the file we maintain about you, and other information we obtainfrom your current and past activities on the Website (1) to deliver theproducts and services that you have requested; (2) to manage your account andprovide you with customer support; (3) to communicate with you by email, postalmail, telephone and/or mobile devices about products or services that may be ofinterest to you either from us, our affiliate companies or other third parties;(4) to develop and display content and advertising tailored to your interestson the Website and other sites; (5) to resolve disputes and troubleshootproblems; (6) to measure consumer interest in our services; (7) to inform youof updates; (8) to customize your experience; (9) to detect and protect usagainst error, fraud and other criminal activity; (10) to enforce our Terms ofUse; and (11) to do as otherwise described to you at the time of collection. Attimes, we may look across multiple users to identify problems. In particular,we may examine your Personally-Identifying Information to identify users usingmultiple user IDs or aliases. We may compare and review yourPersonally-Identifying Information for accuracy and to detect errors andomissions. We may use financial information or payment method to processpayment for any purchases made on the Website, enroll you in the discount,rebate, and other programs in which you elect to participate, to protectagainst or identify possible fraudulent transactions and otherwise as needed tomanage our business.
COLLECTION AND USE OF INFORMATION BY THIRDPARTIES GENERALLY
We take the security of yourPersonally-Identifying Information seriously and use reasonable electronic,personnel and physical measures to protect it from loss, theft, alteration ormisuse. However, please be advised that even the best security measurescannot fully eliminate all risks. We cannot guarantee that only authorizedpersons will view your information. We are not responsible for third-partycircumvention of any privacy settings or security measures.
We are dedicated to protect all information onthe Website as is necessary. However, you are responsible for maintaining theconfidentiality of your Personally-Identifying Information by keeping yourpassword confidential. You should change your password immediately if youbelieve someone has gained unauthorized access to it or your account. If youlose control of your account, you should notify us immediately.
The Children’s Online Privacy Protection Act(“COPPA”) protects the online privacy of children under 13 years ofage. We do not knowingly collect or maintain Personally-Identifying Informationfrom anyone under the age of 13, unless or except as permitted by law. Anyperson who provides Personally-Identifying Information through the Websiterepresents to us that he or she is 13 years of age or older. If we learn thatPersonally-Identifying Information has been collected from a user under 13years of age on or through the Website, then we will take the appropriate stepsto cause this information to be deleted. If you are the parent or legalguardian of a child under 13 who has become a member of the Website or hasotherwise transferred Personally-Identifying Information to the Website, pleasecontact Company using our contact information below to have that child’saccount terminated and information deleted.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also knownas the “Shine The Light” law, permits our users who are Californiaresidents to request and obtain from us, once a year and free of charge,information about the Personally-Identifying Information (if any) we disclosedto third parties for direct marketing purposes in the preceding calendar year.If applicable, this information would include a list of the categories of thePersonally-Identifying Information that was shared and the names and addressesof all third parties with which we shared Personally-Identifying Information inthe immediately preceding calendar year. If you are a California resident andwould like to make such a request, please submit your request in writing to ourprivacy officer as listed below.
Most web browsers and some mobile operatingsystems include a Do-Not-Track (“DNT”) feature or setting you can activate tosignal your privacy preference not to have data about your online browsingactivities monitored and collected. Because there is not yet a common understandingof how to interpret the DNT signal, the Website currently does not respond toDNT browser signals or mechanisms.
If you have any questions regarding our PrivacyPolicy, please contact our Privacy Officer at:
Coin Metrics Inc.Attn: Privacy OfficerOne Broadway – 16th FloorCambridge, MA 02142Email: [email protected]: (617) 407-4837
COPYRIGHT AND LEGAL NOTICE.
Copyright © 2019 Coin Metrics Inc. All Rights Reserved.