I. SCOPE OF THIS PRIVACY STATEMENT
Welcome to Securrency (“Securrency,” “we,” “our,” or “us”). This Privacy Statement applies to our website, www.securrency.com, as well as other websites or mobile applications that are hosted and/or operated by us on behalf of third parties (each, a “Site” and, collectively, the “Sites”). This Privacy Statement describes how we collect, use, disclose and otherwise process personal information about you when you visit a Site, through your use of the services available on a Site (which may be provided by third parties) (“Third Party Services”), submit personal information directly to us on a Site, apply for a job at Securrency through a Site, or otherwise contact us or inquire about or use our products and services (collectively, and together with the Third Party Services, the “Services”). This Privacy Statement does not govern our collection of personal information through any website or other means, other than through a Site.
By using any Site, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not access, browse, or use any of the Sites or any Services. The terms of this Privacy Statement may change from time to time. Your continued use of any of the Sites or any Services is deemed to be acceptance of such changes.
II. WHAT PERSONAL INFORMATION DO WE COLLECT?
A. Information That You or Others Give Us
You do not have to give us any personal information to browse a Site. However, you will be asked to provide personal information to submit or request information from us in order to use the Services offered through a Site or in connection with a position for employment. Once you provide us with personal information about you, you are no longer anonymous to us. This information may include:
- Identification Information: When you inquire about or sign up to receive Services or inquire about or apply for a position with us, you may be required to provide information such as your name, address, phone number, email address, social security or other government identification number, residency information, and citizenship information. When you sign up to receive Services, you may also be required to provide information such as sensitive financial documents, including without limitation bank statements, brokerage statements, asset statements, tax returns, and third party confirmation letters.
- Your Likeness: You may be asked to provide your likeness, typically through a connected camera, to compare your likeness against stored likenesses for the purposes of identity verification.
- Financial Information: In order to obtain the Services through a Site, you may be required to provide financial information in the form of bank account information, routing numbers and/or credit card information, debit card information, as well as a digital- or crypto-wallet address and information relating to such wallet, as well as risk tolerance or investor suitability criteria.
- User Testimonials: You may choose to provide us with user testimonials. This information may be made public to users of a Site and other third parties.
- Additional Information: Additional information that you provide to us may include feedback, messages, emails, and answers to surveys or questionnaires that you may submit, as well as any contact information you provide in order to receive updates from us or from third party service providers.
- Information from and/or on behalf Third Parties: In connection with Services, we may collect information about you from and/or on behalf of third parties, such as professional or financial advisors, credit bureaus, identity verification services and our business partners, in connection with your use of the Services and a Site. For example, we may collect information in connection with verification of identity and accredited investor status of users and to perform KYC and AML checks.
We and our vendors may collect information about you that is publicly available, including from publicly accessible government lists of restricted persons, public databases, media and internet searches and social media sites. We and or our third -party verification providers may also collect information about you from non-public databases of third parties, to the extent permitted under applicable law.
We may also receive information about individuals who do not interact with us directly. For example, our users, vendors, and partners may provide us with personal information about persons other than themselves when using a Site. We require that before we are provided with personal information relating to a third party, that the party providing the information has that individual’s permission or lawful authority to share it with us for processing as described in this Privacy Statement. The types of information we receive about third parties includes information about a potential job candidate or information about a user’s companies, spouses, joint account owners, professional or financial advisors, employees, or referrals.
We ask that you not send us, and you not disclose, any sensitive personal information (e.g., information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic or biometric information, sexual orientation, or criminal convictions or offenses) on any Site or otherwise to us. If you send or disclose any sensitive personal information to us when you use any Services, you consent to our processing and use of such sensitive personal information in accordance with this Privacy Statement. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through a Site.
B. Location Information.
We may collect your physical location information if you use a Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser.
C. Automated Information Collection
We may collect certain information about your use of a Site through the use of tracking technologies or by other passive means. This “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to a Site, search engines used, the internet protocol (IP) address used, the length of time spent on a Site, the pages you looked at on a Site, other websites you visited before and after visiting a Site, the type of internet browser you have, the frequency of your visits to a Site, and other relevant statistics, including the following:
- Log Information. When you access a Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
- Links. A Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of Sites and Services.
- Location Information. We may receive location data passed to us from location-enabled devices or that you have enabled, from your browser, or from third party services.
- URLs. When you visit or access a Site, we automatically receive the URL of the site from which you came and the site to which you are going when you leave a Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on a Site.
- Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed a Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of a Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to a Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
- Aggregate Information. We may compile certain personal information and other information collected through Sites on an aggregate basis. This information may include, without limitation, the number of people who have visited Sites and other user demographics. Such aggregate information does not identify you individually.
III. HOW DO WE USE PERSONAL INFORMATION?
Personal information collected through a Site may be used by us and our affiliates, or licensees of our Services (including the software we have created to issue, maintain and exchange smart digital securities), for purposes of:
- Managing your account and providing the Services through Sites;
- Completing required and best practices regulatory verifications for use of Services through Sites, including verification of your identity by comparing your personal information to government databases and third-party sources;
- Determining whether you are an accredited investor or qualified professional investor (or similar status in applicable jurisdictions) and therefore potentially eligible to participate in certain types of securities offerings, or otherwise receive acquire or hold exempt securities or other types of assets including without limitation smart digital securities;
- Determining your risk tolerance and eligibility suitability to participate in certain types of investment offerings;
- Assigning attributes such as residence, citizenship, accredited investor or professional investor status to digital wallets controlled by you, and using this information to determine whether a digital asset or security may be transferred to such digital wallet in either a primary or secondary offering, including a peer to peer transfer;
- Responding to your questions and feedback;
- Contacting you, whether by email, postal mail, or telephone with information about a Site or Services;
- Distributing notices to you regarding connection your holdings of digital smart securities;
- For such purposes as you may authorize at the time you submit the information;
- Auditing, research, and analysis to maintain, protect, and improve Sites and Services;
- Ensuring the technical functions of our network;
- Improving and customizing the content and layout of Sites;
- Tailoring advertisements to you;
- Developing new products and services;
- Compiling personal information and other information collected through Sites on an aggregate basis;
- Consideration of your application for employment with us and, if you are employed by Securrency, in connection with your employment.
IV. HOW DO WE SHARE PERSONAL INFORMATION?
We do not sell, rent, trade, or otherwise share personal information collected through Sites, except as described below:
- Connection with Services. Provision of the Services to you may require that we share certain personal information with third parties. Such third parties may include third parties involved in the provision of Services such as the third-party service providers that use Sites to make services available to you (such as the issuer and the issuer organizers), professional or financial advisors, and/or those that provide identity verification, website hosting, marketing, exchange, analytics and fulfillment services. We may also store personal information in our attribute registration service and make it available to the market in connection with potential transactions that utilize our rules engine to ascertain whether transaction logic is satisfied.
- Connection with Employment. Consideration of your application of employment or your employment, may require that we share certain personal information with third parties. Such third parties may include third party service providers relating to payroll, immigration and background checks and other professional or financial advisors.
- Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
- Consent. We may share personal information in accordance with any consent you provide.
- Connection with Potential Exchange Transactions. Your personal information may be shared with securities exchanges, broker dealers, financial institutions, or other persons for compliance purposes or for the purpose of evaluating your suitability or desire to participate in an exchange or sale transaction or to market their services to you or to offer digital securities or other assets to you.
- Required by Law. We may disclose personal information or any information collected through Sites if we are required to do so by law (e.g., for purposes of completing required verifications for provision of the Services to you) or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
- Advisors and Certain Transactions. We may disclose or transfer personal information or any information collected through Sites to third parties who provide services to us (such as auditors, accountants, attorneys, CPAs and other professional advisors) and/or to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
By using any Site you agree to usage tracking and targeted, behavioral advertising. If you do not wish to have cookies track your usage for these purposes please see the Section II.C of this Privacy Statement to refuse all or some browser cookies or do not use any Site.
Some advertisers may provide you with the choice to opt-out of having your information used for behavioral advertising. If you would like more information about behavioral advertising, or for information about how to opt-out of behavioral advertising, please visit the Network Advertising Initiative’s (“NAI”) consumer Web site at https://www.networkadvertising.org/understanding-online-advertising, and in particular, NAI’s Ad Network “Opt-Out” page at https://www.networkadvertising.org/choices/. Even if you opt-out of behavioral advertising, we may still collect and use information about your use of a Site to the extent otherwise permitted by this Privacy Statement (such as to analyze Site traffic and usage, conduct website analytics, administer a Site, etc.). In addition, if you opt-out of receiving behavioral advertising from a particular advertiser, the advertiser may still provide advertisements to you, but the ad will not be targeted to you based on your online activities.
V. AGGREGATE INFORMATION
We may compile personal information and other information collected through Sites on an aggregate basis. This information may include, without limitation, the number of users who have registered for a Site or Sites, demographic information about users of any Site, and individual preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.
VI. YOUR CHOICES
A. Information You Provide
You can always choose whether or not to provide information on a Site. However, if you choose not to disclose certain information, you may not be able to receive Services or access certain portions of a Site.
B. Your Rights to Your Information
When you provide personal information to us, you retain the right to be informed of how your information is being used, right of access to your information, right of rectification to your information, right to erasure of your information, right to restrict processing of your information, right of information portability, right to object and right to not to be subject to profiling with your information. You have also have the right to review, edit or delete your information at any time.
If you wish to have your personal information edited, deleted, or audited, please contact us any time at [email protected] and our information officers will be able to accommodate your requests.
C. Communications From Us
If at any time you decide that you no longer wish to receive notices from us regarding a Site, you may indicate this preference by contacting us at [email protected]
D. Do Not Track
The Sites do not honor “do not track” signals or other mechanisms. However, as described in more detail in Section II.C of this Privacy Statement, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.
VII. INFORMATION STORAGE AND SECURITY
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Sites. These security measures include the following:
- All stored personal information is encrypted using IEncryption library, using 256-bit AES algorithms.
- Uploaded user documents used for investor status verification are encrypted for storage using 256-bit AES algorithms.
- Multi-tier server architecture is used to safeguard user data. The Web layer is located in a DMZ and a Web Application Firewall is used to isolate server infrastructure from internet-based attacks.
- We employ Secure Socket Layer (SSL) technology to secure and encrypt communications between Sites and web browsers.
However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with a Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
We will not retain personal information longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Users with an active account have the ability to request that we delete their personal information at any time. When a user makes a request to have their account deleted and all personal information deleted, all personal information of that user collected through such Site will be deleted, as required by applicable law.
VIII. A SPECIAL NOTE ABOUT CHILDREN
Children are not eligible to use any Site, and we ask that minors (children under the age of majority in the country in which they reside) not submit any personal information to us.
IX. EXTERNAL LINKS
X. SPECIAL ADMONITIONS FOR INTERNATIONAL USE
Securrency is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to 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.
XI. CALIFORNIA PRIVACY RIGHTS
California residents may elect to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at Securrency, 110 Corcoran Street, Suite 5-142, Durham, NC 27701, Attention: Privacy Officer.
XII. UPDATES TO THIS PRIVACY STATEMENT
We may change or update any Site or any of our policies and procedures without prior notice. We will post a notice on www.securrency.com to advise you of any significant changes to this Privacy Statement and indicate via the “Last Updated” legend at the top of this Privacy Statement when it was most recently updated. Your continued use of a Site signifies your continued assent to the terms of this Privacy Statement, as updated or amended at that time.
XIII. QUESTIONS REGARDING THIS PRIVACY STATEMENT
If you have any questions or comments regarding this Privacy Statement, please send us an email at [email protected].