Privacy Policy
Last modified: July 31, 2023
This privacy policy (the “Policy”) of Terminal 0 Ltd. (“Company” or “our” or "we" or “us”) describes how we and our affiliates collect, use, and disclose information, and your choices regarding this information. Please read this policy carefully and contact us with questions at [TBD].
Applicability of This Policy
This Policy applies to the Services (as defined in the Terms of Use (the "Terms")), including the Interface. If you do not agree with the terms of this Policy, do not access or use any Services.
What We Collect
When you interact with the Services, we may collect:
Contact information, such as your name, email address, physical address and country information.
Financial information, such as your Ethereum network address, cryptocurrency wallet information, transaction history, trading data and associated fees paid.
Transaction information, such as information about the transactions you make on our Services, such as the type of transaction, transaction amount, and timestamp.
Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat or social media messaging channels.
Online identifiers, such as username, geo location or tracking details, browser fingerprint, operating system, browser name and version, and IP addresses.
Usage and diagnostics data, such as conversion events, user preferences, crash logs, device information and other data collected via cookies and similar technologies.
Information we get from others. We may get about you from other sources as required or as permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from your use of Services in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.
Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of the Services, including our mobile applications, and collect information about the use of the Services, as well with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Services may not function properly.
How We Use Information
We use your information in accordance with your instructions, including any applicable terms in the Terms, and as required by applicable law. We may also use the information we collect for:
Providing Services and Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services. This includes using information to:
Operate, maintain, customize, measure, and improve Services, and manage our business;
Create and update user accounts;
Process transactions;
Send information, including confirmations, notices, updates, security alerts, and support and administrative messages; and
To create de-identified or aggregated data.
Safety and Security. We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
Monitor and verify identity or service access, combat spam, malware or security risks;
Perform internal operations necessary to provide Services, including to troubleshoot software bugs and operational problems;
Enforce our agreements with third parties, and address violations of Terms or agreements for other products or services; and
Comply with applicable security laws and regulations.
Customer Support. We may use information we collect to provide customer support, including to:
Direct questions to the appropriate customer support person;
Investigate and address user concerns; and
Monitor and improve our customer support responses and processes.
Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of Services, improve our ability to prevent the use of Services for illegal or improper purposes, and develop new features and products relating to Services.
Direct Marketing. We may use the information we collect to market Services to you. This may include sending you communications about Services, features, promotions, surveys, news, updates, and events. If you do not want us to send you marketing communications, please unsubscribe using the link provided in such communications.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
How We Share and Disclose Information
We may share your information in the following circumstances:
With Your Consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subiect to their privacy policies.
To Comply with Our Legal Obligations. We may share your information: (a) to cooperate with government investigations; (b) when we are compelled to do so by a subpoena, court order, or similar legal procedure; (c) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person; (d) to report suspected illegal activity; or (e) to investigate violations of Terms, agreements for other products or services, or any other applicable policies.
With Professional Advisors. We share information with our professional advisors for purposes of audits and compliance with our legal obligations.
With Service Providers or Other Third Parties. We may share your information with service providers or other third parties who help facilitate business and compliance operations, such as marketing and technology services.
With Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
During a Change to Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may share aggregated or anonymized data with other persons for their own uses.
Data Retention
To view or update your information, contact us at legal@term.finance. We store your information throughout the life of your use of Services and thereafter.
Security
We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure and require our third-party service providers to have appropriate safeguards. No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will remain secure against unauthorized access or disclosure. You are responsible for all use of Services relating to any of your Ethereum network addresses or cryptocurrency wallets.
Age Limitations
We do not allow use of Services by anyone younger than 18 years old. If you learn that anyone younger than 18 years old has unlawfully provided us with personal data, please contact us at legal@term.finance and we will takes steps to delete such information, close any such accounts, and, to the extent possible, prevent the user from continuing to use Services.
Changes to This Policy
If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed.
Online Tracking Opt-Out Guide
Like many companies online, we may use services provided by companies that use tracking technology. These services rely on tracking technologies—such as cookies and web beacons—to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for internet-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies or trackers.
Platform opt-outs. The following advertising partner offers opt-out features that let you opt-out of use of your information for interest—based advertising:
Google: https://adssettings.google.com
Advertising industry opt-out tools. You can also use the opt-out options set forth below to limit use of your information for interest-based advertising by participating companies. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org
Additional Disclosures for Data Subjects in the European Economic Area and the United Kingdom
A. Roles.
The General Data Protection Regulations in the European Economic Area and the United Kingdom (“GDPR”) distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Services.
B. Lawful Basis for Processing.
The GDPR requires a “lawful basis” for processing personal data. Our lawful bases include where: (i) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; or (iv) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Data Subject Rights
If you are a user in the European Economic Area or the United Kingdom, you maintain certain rights under the GDPR. These rights include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure of your personal data; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.
Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any NFTs held by your wallet address.
To exercise any of these rights, please contact us via legal@term.finance. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, please contact us as set out in the “Contact Us” section above. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction.
Additional Disclosures for California Residents
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and the means to exercise consumer rights.
A. Notice of Collection.
We collect the following categories of personal information enumerated in the CCPA:
Internet activity, including information on visitors to the Website and their interactions with the Services.
Geolocation data of Website visitors.
For further details on the information we may collect, including the sources from which we receive information, review the “What We Collect” section above. We may collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage the Services. We do not “sell” personal information as defined under the CCPA. Please review the “How We Use Information” section above for further details about the categories of parties with whom we share information.
B. Right to Know and Delete.
You have the right to know certain details about our data practices within the past twelve (12) months. In particular, you may request the following from us
The categories of personal information we have collected about you.
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose;
The categories of third parties to whom the personal information was disclosed for a business purpose;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you
In addition, you have the right to delete the personal information we have collected from you. To exercise any of these rights, please submit a request by emailing us at legal@term.finance. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
C. Authorized Agent.
You may designate an authorized agent to submit requests on your behalf; however, we may require written proof of the agent’s permission to act on your behalf and verify your identity directly
D. Right of Non-Discrimination.
You have a right of non-discrimination for the exercise of any of your privacy rights guaranteed by law, such as the right to access, delete, or opt-out of the sale of your personal information.
E. Shine the Light.
Residents of California who are permitted users of Services may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write to us at the email above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once per calendar year.
Additional Disclosures Regarding the Interface
This section governs our collection, use, and sharing of personal information provided by users of the Interface. To the extent there are conflicting provisions between this section and other sections of this Policy, this section will govern.
The types of personal information we collect and share can include:
Cryptoasset balances and wallets
IP addresses
Transaction history
Notwithstanding anything to the contrary in this Policy, when you are no Ionger a user of Services, we continue to share your information as described in this section.
Reasons We Can Share Your Personal Information
We need to share users’ personal information to operate certain aspects of our business. Whether we share your personal information, the reasons for which we share your personal information, and whether you can limit this sharing include the following:
We share users’ personal information for our everyday business purposes, such as to respond to court orders and legal investigations. You cannot limit our sharing of this information.
We share users’ personal information for our marketing purposes, such as to offer Services to you. You cannot limit our sharing of this information.
We do not share users’ personal information for joint marketing with financial companies.
We do not share users’ personal information for our affiliates’ everyday business purposes.
We do not share users’ personal information for our affiliates to market to you.
We share users’ personal information for nonaffiliates to market to you.
Contact Us
If you have any questions or comments about this Policy, our data practices, or our compliance with applicable law, please contact us:
By email: legal@termfinance.io
Last updated