COMPANY

CM Privacy Policy

 

Version Date: February 19, 2019

GENERAL

Coin Metrics Inc. (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at www.coinmetrics.io, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of thisPrivacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website andyour agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawfulin their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU AREACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

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.

Web Cookies

A “Web Cookie” is a string of information whichassigns you a unique identification that a website stores on a user’s computer,and that the user’s browser provides to the website each time the user submitsa query to the website. We use cookies on the Website to keep track of servicesyou have used, to record registration information regarding your login name andpassword, to record your user preferences, to keep you logged into the Websiteand to facilitate purchase procedures. Company also uses Web Cookies to trackthe pages that users visit during each Website session, both to help Companyimprove users’ experiences and to help Company understand how the Website isbeing used. As with other Non-Personally-Identifying Information gathered fromusers of the Website, Company analyzes and discloses in aggregated forminformation gathered using Web Cookies, so as to help Company, its partners andothers better understand how the Website is being used. COMPANY USERS WHO DONOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIRBROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THEUNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLYWITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALLRESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

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.

Analytics

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.

SOCIAL MEDIA 

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

Website Registration

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.

Online Postings

Certain Personally-Identifying Information collected from users may bedisclosed as a matter of course as a result of your use of the Website. We mayprovide areas on the Website where you can post reviews and other informationrelating to your activities on the Website. Such postings are governed byour Terms of Use. In addition, such postings may appear on other websitesor when searches are executed on the subject of your posting. Also, wheneveryou voluntarily disclose personal information on publicly-viewable web pages,that information will be publicly available and can be collected and used byothers. For example, if you post your email address, you may receiveunsolicited messages. We cannot control who reads your posting or what otherusers may do with the information you voluntarily post, so we encourage you toexercise discretion and caution with respect to your personal information.USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTINGFROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications

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 Disclosures

Company will disclose Personally-IdentifyingInformation under the following circumstances:

•By Law or to Protect Rights. When we believe disclosure is appropriate, wemay disclose Personally-Identifying Information in connection with efforts toinvestigate, prevent or take other action regarding illegal activity, suspectedfraud or other wrongdoing; to protect and defend the rights, property or safetyof Company, our users, our employees or others; to comply with applicable lawor cooperate with law enforcement; to enforce our Terms of Use or otheragreements or policies, in response to a subpoena or similar investigativedemand, a court order or a request for cooperation from a law enforcement orother government agency; to establish or exercise our legal rights; to defendagainst legal claims; or as otherwise required by law. In such cases, we mayraise or waive any legal objection or right available to us.

•   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.

•Business Transfers; Bankruptcy. Company reserves the right to transfer allPersonally-Identifying Information in its possession to a successororganization in the event of a merger, acquisition, bankruptcy or other sale ofall or a portion of Company’s assets. Other than to the extent ordered by abankruptcy or other court, the use and disclosure of all transferredPersonally-Identifying Information will be subject to this Privacy Policy, orto a new privacy policy if you are given notice of that new privacy policy andare given an opportunity to affirmatively opt-out of it. Personally-IdentifyingInformation submitted or collected after a transfer, however, may be subject toa new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information;Account Termination

You may at any time review or change yourPersonally-Identifying Information by going to your account settings (ifapplicable) or contacting us using the contact information below.  Uponyour request, we will deactivate or delete your account and contact informationfrom our active databases. Such information will be deactivated or deleted assoon as practicable based on your account activity and accordance with ourdeactivation policy and applicable law. To make this request, either go to youraccount settings (if applicable) or contact us as provided below. We willretain in our files some Personally-Identifying Information to prevent fraud,to troubleshoot problems, to assist with any investigations, to enforce ourTerms of Use and to comply with legal requirements as is permitted by law.Therefore, you should not expect that all your Personally-IdentifyingInformation will be completely removed from our databases in response to yourrequests. Additionally, we keep a history ofchanged information to investigate suspected fraud with your account.

General Use

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

Company contractually prohibits its contractors,affiliates, vendors and suppliers from disclosing Personally-IdentifyingInformation received from Company, other than in accordance with this PrivacyPolicy. However, third parties are under no obligation to comply with thisPrivacy Policy with respect to Personally-Identifying Information that usersprovide directly to those third parties, or that those third parties collectfor themselves. These third parties include advertisers, providers of games,utilities, widgets and a variety of other third-party applications accessiblethrough the Website. Company neither owns nor controls the third-party websitesand applications accessible through the Website. Thus, this Privacy Policy doesnot apply to information provided to or gathered by the third parties thatoperate them. Before visiting a third party, or using a third-partyapplication, whether by means of a link on the Website, directly through theWebsite or otherwise, and before providing any Personally-IdentifyingInformation to any such third party, users should inform themselves of theprivacy policies and practices (if any) of the third party responsible for thatwebsite or application, and should take those steps necessary to, in thoseusers’ discretion, protect their privacy.

SECURITY

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.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change thisPrivacy Policy from time to time. Any and all changes to Company’s PrivacyPolicy will be reflected on this page and the date new versions are posted willbe stated at the top of this Privacy Policy. Unless stated otherwise, ourcurrent Privacy Policy applies to all information that we have about you andyour account. Users should regularly check this page for any changes to thisPrivacy Policy. Company will always post new versions of the Privacy Policy onthe Website. However, Company may, as determined in its discretion, decide tonotify users of changes made to this Privacy Policy via email or otherwise.Accordingly, it is important that users always maintain and update their contactinformation.

CHILDREN

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.

DO-NOT-TRACK POLICY

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.

CONTACT

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.