Thank you for visiting blockchains.com, a Website owned by Blockchains, Inc. (“Blockchains”, “our”, “we” or “us”). Your privacy and your rights concerning your privacy are important to us. This Privacy Policy, as amended or otherwise changed from time to time (the “Privacy Policy”), explains the manner in which we collect, use, maintain and disclose user information obtained through the Website. By using the Website, you (“User”) consent to the data practices prescribed in this Privacy Policy. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Use.

Your Consent.

By using or accessing the Website, you agree to the terms of this Privacy Policy, the Cookie Policy, and the Terms of Use. Whenever you submit information to us on or through this site, through a mobile device, or otherwise, you consent to the collection, use, transfer, and disclosure of that information in accordance with this Privacy Policy and applicable law. If you do not agree with this Privacy Policy, please do not use our sites and please do not submit any personal information to use through a mobile device or otherwise.

About Children.

This site is not intended for children under the age of 18. We do not knowingly collect personally identifiable information via this site from visitors in this age group.  If a user submitting personal information is suspected of being younger than 18 years of age, Blockchains will take steps to delete the information as soon as possible. We encourage parents to talk to their children about their use of the Internet and the information they disclose to websites.

Personally Identifiable Information.

We define Personally Identifiable Information (“PII”) as any information about an individual, including (1) any information that can be used, directly or indirectly, to distinguish or trace an individual’s identity, such as name, social security number, date and place of birth, mother’s maiden name, location information, or biometric records; and (2) any other information that is linked or linkable to an individual, such as email addresses and medical, educational, financial and employment information.

Information you Provide.

You can view most of our content anonymously. Should you sign up to receive email notifications from us, we will collect and maintain your name, email address, and zip/postal code until, and unless, you click the unsubscribe link located at the bottom of any marketing or newsletter emails that have been sent to you by us and complete a brief questionnaire regarding your subscription preferences.

If you have applied for a position through the Careers page on the Website, we collect your name, phone number, email address, and any information included in your resume, including your date of birth, education history, military service, immigration status, employment history, and information about references you identify. We will only retain such PII so long as is necessary for the purposes for which we are processing the PII.

Our Website may allow you to enter social networking websites such as Facebook, Twitter, LinkedIn, and YouTube, among others. If you choose to follow, like, friend, share, or comment on our social media websites, we may receive information about you. We may keep all of this information indefinitely.

Please do not submit any personal information if you do not want it to be collected. You do not have to provide PII to us to use this site.

Passive Information Collection.

When you visit the Website, we also collect other information through cookies such as traffic sources, conversion rates and your IP address; however, we do not use this information to gather any additional PII. Please view our Cookie Policy for additional information.

Use of Information

Except as otherwise stated, we may use information collected via this site, through a mobile device, or otherwise, to improve the content of our site, to customize the site to your preferences, to communicate information to you (if you have requested it), for our marketing and research purposes, and for any other purpose specified in this Privacy Policy. In addition, we may make full use of all information acquired through this site that is not in personally identifiable form. If you provide PII to this site, we may combine such information with other actively collected information unless we specify otherwise at the point of collection.

The PII we collect will not be given or sold to third parties. We may disclose PII you provide through this site, through a mobile device or otherwise, to other Blockchains affiliates worldwide that agree to treat it in accordance with this Privacy Policy and use it for the same purposes.

We may also use the PII we collect:

• To enforce the legal terms (including but not limited to our Terms of Use) that govern your use of the Website.
• For the purposes for which you provided the PII.
• To respond to your questions and/or comments.
• To provide technical support for the Website.
• To prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Website; or
• To protect the safety of our Users, for example, when we believe it necessary to share information to assist in an investigation regarding, or to prevent, illegal activities, suspected fraud, or potential threats to the safety of any person.

Emma. When sending emails to our Users who have signed up to receive email announcements, we use the Emma service to send such emails. This sharing enables us to inform our Users of updates in the most efficient way possible. Emma is required to follow the same data security practices to which we adhere.

Third-party Vendors. In the operation and maintenance of the Website, we use third-party vendors such as business analytics and fraud prevention. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information collected for any other purpose. The third-party vendors are also required to follow the same data security practices to which we adhere.

In addition, we also may share your information:

• In response to legal process, for example, a court order or a subpoena, a law enforcement or government agency’s request, or similar request. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
• To third parties in order to investigate, prevent or take action (in our sole and absolute discretion) regarding potentially illegal activities; suspected fraud; situations involving potential threats to any person, us or the Website; or violations of the law, our Terms of Use or to verify or enforce compliance with the Terms of Use governing the Website.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
• We may also share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose the number of visitors to our Websites or the number of people who have downloaded a particular document.

Other than as stated in this Privacy Policy, we do not disclose any of your PII to any other third parties.

Security.

We want you to feel confident when using the Website, and we are committed to protecting the information we collect. However, you should keep in mind that the Website runs on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. While no website can guarantee security, we use industry-standard data encryption technology, and we have implemented appropriate administrative, technical, and physical security procedures to help protect the PII you provide to us and protect all user data we collect against any unauthorized access. For example, only authorized employees are permitted to access PII, and they may only do so for permitted business functions. In addition, we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.

Additional Rights with Respect to Information we Collect.

You can choose not to provide us with any PII, in which case:

• You will be given the opportunity to unsubscribe from emails in any email we send you; and/or
• You can assert your rights as specified below.

Depending on applicable law where you reside, you may be able to assert certain rights related to your PII. If any of the rights listed below are not provided under law for your jurisdiction, Blockchains has absolute discretion in providing you with those rights.

As a User of the Website, you have various rights regarding the information we collect. Please note, all rights are subject to an initial check regarding whether any PII data of the person seeking information is being processed at all. If yes, you are entitled to a right of access, which allows you exercise further rights such as rectification and erasure. It is important to understand that your rights to personal information are not absolute. Depending on the applicable law, access may be denied. Such rights and potential limitations include:

• Right to rectification. You may request that we rectify any inaccurate or incomplete PII.
• Right to withdraw consent. You may, at any time, withdraw your consent to the processing of your PII. Such withdrawal will not affect the lawfulness of our processing based on your previous consent.
• Right to make a PII access request. You may request in writing, copies of your PII. Each request should make clear that a PII access request is being made. You may also be required to submit proof of your identity, when applicable. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.
• Right to erasure. You may request that we erase your PII and non-PII, subject to applicable law. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the PII and/or non-PII, such as, business record retention obligations with which we must comply. Should Blockchains be unable to comply with a right to erasure request, the legal basis for keeping the PII shall be communicated to you pursuant to Article 13 and 14 of the General Data Protection Regulation (“GDPR”).
• Right to restrict processing. You may request that we limit the way we use your PII under the following circumstances:
  • You contest the accuracy of your PII and want to verify the accuracy of such PII;
  • Your PII has been unlawfully processed and you would rather restrict your PII rather than request we delete it;
  • We no longer need your PII, but you need us to keep it in order to establish, exercise or defend a legal claim; or
  • You have objected to us processing your data under Article 21(1) of the GDPR, and we are investigating the validity of your objections.

We will comply with such request, unless there is a lawful reason for not doing so, including: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

• Right to data portability. You may request that we provide a copy of your PII and/or non-PII in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. To the extent possible, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of your PII and non-PII, which may still be retained for legitimate and lawful purposes.
• Right to lodge a complaint with the supervisory authority. We encourage you to contact us about any questions or complaints in relation to how we process your PII and non-PII. However, each User has the right to contact the relevant supervisory authority directly.

Should you want to exercise any of your rights listed above, please contact our Data Protection Officer at BlockchainsDPO@Blockchains.com.

If you reside in the EU, you can file a complaint with the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting the website http://info.adr.org/safeharbor, or your relevant data protection authority.

In the UK, the relevant data protection authority is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113, casework@ico.org.uk.

In Ireland, the relevant data protection authority is the Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois; phone: +353 (0761) 104 800; LoCall: 1890 25 22 31; Fax: +353 57 868 4757; email: info@dataprotection.ie

Changes to this Privacy Policy

We may update this Privacy Policy in the future to reflect changes in law, our PII and non-PII collection and use practices, the features on the Website, or advances in technology. We will notify you about material changes to this Privacy Policy by sending a notice to the email address you provided us and/or by posting a new a revised Privacy Policy with a new “Last Updated” date.

The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices with respect to our Website. We encourage you to check frequently to see the current Privacy Policy to be informed of how Blockchains is committed to protecting your information and providing you with improved content on our Website in order to enhance your experience.

How to Contact Us or Opt Out

If you decide you no longer wish to receive communications from us, you may opt out at any time by emailing privacy@blockchains.com or by following the link to unsubscribe in any email that has been sent to you by Blockchains.

If you have any questions, concerns, or comments about the foregoing Privacy Policy as outlined above, please contact us at privacy@blockchains.com.

This Privacy Policy was last updated on December 15, 2020.