Last Updated: August 6, 2019
Your privacy is important to us. At EBO, we follow a few fundamental principles:
We don’t ask you for personally identifiable information (defined below). That being said, your contact information, such as your phone number, social media handle, or email address (depending on how you contact us), may be collected when you communicate with us or if you report a bug or other error related to EBO.
We don’t share your information with third parties except to deliver you our Services and products, comply with the law, make EBO better, protect our rights, or effectuate a business transfer.
We’re not a huge, faceless corporation. We’re just developers trying to deliver an incredible product. If you have any questions or concerns about this policy, please reach out to us at email@example.com.
HOW YOU ACCEPT THIS POLICY
WHAT PERSONAL INFORMATION DO WE COLLECT FROM OUR USERS?
The information we collect from you falls into two categories: (i) personally identifiable information (i.e., data that could potentially identify you as an individual) (“Personal Information”), and (ii) non-personally identifiable information
We do our best NOT to collect any Personal Information from EBO users. We may collect some Personal Information from you when you communicate with us, including your contact information, such as your phone number, social media handle, or email address (depending on how you reach out).
Like other online services, we also collect a variety of Non-Personal Information, including:
Information you create through the Trust Wallet’s website or mobile applications.
Various analytics data, such as: (i) the IP address of the computer you use to access EBO; (ii) the type of browser software you are using; (iii) the operating system you are using; (iv) the date and time you access or use EBO; (v) the website address, if any, that linked you to EBO; (vi) the website address, if any, you leave our website and travel to; and (vii) other non-personally identifiable traffic data.
HOW WE COLLECT INFORMATION
When You Contact Us.
We may collect certain information if you choose to contact us, if you use our Services or if you report a bug or other error with EBO. This may include contact information such as your name, email address, phone number, and public wallet address. We, or companies that provide services on our behalf, may also collect certain Non-Personal Information from you, such as your locally hosted public wallet (a “Wallet”) addresses.
Information We Automatically Collect
Users who visit our website or use our application may have their device’s IP address logged for the purpose of generating anonymous statistics or troubleshooting the performance of our web servers. Your IP address will not be used to track or identify you, but may be used to determine your geographic location in order to determine which of our services you are presented with.
Third Party Services
Certain features on EBO Wallet rely on various third-party products and services (collectively “Third Party Services”), such as the Ethereum network, Google Analytics, Apple’s application platform and Simplex.com.
These services may collect certain Personal Information, such as your public Wallet addresses.
HOW WE USE THE INFORMATION WE GATHER
We primarily use the limited information we collect to enhance EBO. Except if we sell all or a portion of our business, or as otherwise described below, we do not rent, trade, or sell your Personal Information.
Use of Information to Provide EBO to You
Some ways we may use your Personal Information are to:
Contact you when necessary;
Respond to your comments, questions, or issues related to bugs or errors with EBO;
Provide you with additional information;
Send you information and marketing materials about services and products available through EBO, using push notifications or other means;
Train our team members; or
Other internal business purposes.
Aggregated Personal Data and Non-Personal Information
We may share or disclose aggregated Personal Data or Non-Personal Information with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the company. These service providers and other persons may also share with us aggregated Non-Personal Information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, web beacons, and cookies with similar data we collect from other visitors to help us improve our Services. When doing so, we do our best to ensure that the any aggregated information cannot be linked back to you.
Agents or Third Party Partners
We may provide your Personal Information to our employees, contractors, agents, service providers, and designees (“Agents”) to enable them to perform certain services for us exclusively, including:
Improvement of website-related services and features; and Perform maintenance services.
Protection of Us and Others
WHAT PERSONAL INFORMATION CAN I ACCESS OR CHANGE?
You can request access to the information we have collected from you. You can do this by contacting us at firstname.lastname@example.org. We will make sure to provide you with a copy of the data we process about you. To comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically. For any subsequent access request, we may charge you with an administrative fee.
If you believe that the information we have collected is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for purposes specified in the “How We Use the Information We Gather” section will be deleted after ninety (90) days.
If at any point you wish for EBO to delete information about you, you may contact us at email@example.com.
If you delete your EBO application or uninstall your EBO application from your devices, or request that your information be deleted, we still may retain some information that you have provided to us to maintain EBO or to comply with relevant laws.
We are committed to making sure your information is protected and have selected third-party vendors which use the Ethereum network that help keep your Personal Information safe. Unfortunately, we do not control these third parties and therefore cannot guarantee complete security.
We employ several physical and electronic safeguards to keep your information safe, including encrypted user passwords, two factor verification and authentication on passwords where possible, and securing all connections with industry standard transport layer security.
Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk.
ONLINE TRACKING AND HOW WE RESPOND TO DO NOT TRACK SIGNALS
Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If an online service elects to respond to a particular DNT signal, the service may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many website operators, including EBO, do not take action to respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
NOTICE TO EU DATA SUBJECTS
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at firstname.lastname@example.org.
Processing Purpose Legal Basis
To communicate with you
To optimize our platform
For compliance, fraud prevention, and safety
To provide our service
These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
With your consent
Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at email@example.com.
Use for New Purposes
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at email@example.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
What is a Cookie?
A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. You can find out more about each cookie by viewing our current cookie list below. We update this list periodically, so there may be additional cookies that are not yet listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.
To recognize new or past customers.
To store your password if you are registered on our Site.
To improve our Site and to better understand your visits on our platforms and Site.
To integrate with third party social media websites.
To serve you with interest-based or targeted advertising.
To observe your behaviors and browsing activities over time across multiple websites or other platforms.
To better understand the interests of our customers and our website visitors.
Some Cookies are necessary for certain uses of the Site, and without such Cookies, we would not be able to provide many services that you need to properly use the Site. These Cookies, for example, allow us to operate our Site so you may access it as you have requested and let us recognize that you have created an account and have logged into that account to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.
We also use functional Cookies and Cookies from third parties for analysis and marketing purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known. Analysis Cookies, among other things, collect information on how visitors use our Site, the content and products that users view most frequently, and the effectiveness of our third party advertising. Advertising Cookies assist in delivering ads to relevant audiences and having our ads appear at the top of search results. Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the cookie.
How to disable Cookies.
If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance.
If you are located in the European Economic Area, you have certain rights that are described above under the header “Notice to EU Data Subjects”, including the right to inspect and correct or delete the data that we have about you.
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