Privacy Police
This Privacy Policy ("Policy") describes how Good Randomness Limited. ("the PAC," "we," "us" or "our") may collect, use and disclose information, and your choices regarding this information. Please read this Policy carefully and contact us with questions at support@thepac.io
Applicability of This Policy
This Privacy Policy governs your use of our services, including those offered through our platform, the user interface for the Protocol, and any other websites, pages, features, mobile applications, or content we own or operate (collectively referred to as the "Sites"). It also applies to the use of our APIs, whether accessed directly or via third-party applications that rely on them, as well as any related services (collectively, the "Services"). If you do not agree to the terms outlined in this Policy, please refrain from accessing or using the Sites, Services, or any other part of our operations.
What We Collect
When you interact with our Services, we may collect the following types of information:
Contact Information: Your email address or other contact details.
Financial Information: Your Ethereum address, cryptocurrency wallet details, transaction history, and any associated fees paid.
Transaction Information: Details about transactions performed using our Services, including the type of transaction, transaction amount, and timestamps.
Correspondence: Information you share through feedback, questionnaires, surveys, or interactions with our support team, including communications via our help chat.
Online Identifiers: Data such as your geolocation, browser fingerprint, operating system, browser name and version, and personal IP address.
Usage Data: Information like user preferences and other data collected via cookies or similar tracking technologies.
Information from Third Parties: Details obtained from external sources, as required or permitted by applicable law, including public databases, credit bureaus, and ID verification partners. We may combine this information with data collected through our Site to fulfill legal obligations and prevent the misuse of our Services for fraudulent or illicit activities.
Cookies and Tracking Technologies: We, along with authorized third parties, use cookies and similar tools on our Sites and mobile applications to gather data about your interactions with the Services. This may include your IP address, browser type, internet service provider (ISP), referring/exit pages, operating system, timestamps, clickstream data, and how you engage with our communications. We may merge this automatically collected data with other information we collect about you. You can configure your web browser to refuse cookies or alert you when cookies are being sent. However, please note that some features of our Services may not function properly if cookies are disabled.
How We Use Information
We use your information in accordance with your instructions, including any applicable terms in the Terms of Use, and as required by applicable law. We may also use the information we collect for: Providing Services and FeaturesWe may use the information we collect to deliver, personalize, maintain, and enhance our products and Services, as outlined in our Terms of Use. This includes:
operating, maintaining, customizing, measuring, and improving our Services, as well as managing our business operations;
processing and facilitating transactions;
sending essential communications, such as confirmations, notices, updates, security alerts, and support or administrative messages;
generating de-identified or aggregated data for analytical and lawful purposes.
Safety and SecurityWe may use your information to ensure the safety, security, and integrity of both you and our Services. This includes:
protecting against, investigating, and deterring fraudulent, unauthorized, or illegal activities;
monitoring and verifying identity or service access, and addressing risks such as spam, malware, or other security threats;
conducting internal operations necessary for providing our Services, including troubleshooting software bugs and resolving operational issues;
enforcing agreements with third parties and addressing violations of our Terms of Use or other Service-related agreements;
complying with applicable security laws, regulations, and industry standards.
User SupportWe may use information we collect to provide support, including to:
direct inquiries to the appropriate support personnel;
investigate and resolve user concerns; and
monitor and enhance our customer support processes and response quality.
Research and DevelopmentWe may use the information we collect for testing, research, analysis, and product development. These efforts aim to:
enhance your overall experience with our Services;
improve and strengthen the safety and security of our platform;
advance our ability to prevent the misuse of our Services for illegal or improper purposes;
develop new features, functionalities, and products related to our Services.
Legal and Regulatory ComplianceWe may verify your identity by cross-referencing the personal information you provide with third-party databases and public records. Additionally, we may use the information we collect to investigate or address claims, disputes, or issues related to your use of our Services. This may also include compliance with applicable laws, or as required by regulators, government agencies, or official inquiries. Direct MarketingWe may use the information we collect to promote our Services to you. This may include sending communications about our Services, features, promotions, surveys, news, updates, and events, as well as managing your participation in such activities. If you prefer not to receive marketing communications from us, you can opt out by selecting "unsubscribe" in any marketing email we send or by contacting us at support@thepac.io.
How We Share & Disclose Information
We may share your information in the following circumstances:
With Your Consent: For example, you may choose to allow us to share your personal information with third parties for their own marketing purposes. These uses will be subject to the third parties' privacy policies.
To Comply with Our Legal Obligations: We may share your information in order to:
Cooperate with government or regulatory investigations.
Comply with a subpoena, court order, or similar legal process.
Disclose personal information when we believe, in good faith, that it is necessary to prevent harm to another person.
Report suspected illegal activity.
Investigate violations of our User Agreement or other applicable policies.
With Service Providers: We may share your information with third-party service providers who assist with business and compliance operations, such as marketing and technology services. Our contracts with these providers require them to use your information solely for the services they perform on our behalf.
During a Change to Our Business: In the event of 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 part of our business, or any similar transaction or proceeding (including steps taken 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 and/or anonymized data with third parties for their own purposes.
Data Retention
To view or update your information, please contact us at support@thepac.io. We retain your information for as long as you use the Protocol and for a minimum of five (5) years to comply with our legal obligations or to resolve any disputes. If you stop using the Protocol, we will no longer use your information for any purposes, nor will we sell or share it with third parties, except as necessary to prevent fraud, assist law enforcement, comply with legal requirements, or as outlined in this Policy.
Security
We implement administrative, technical, and physical safeguards designed to protect the personal information we maintain from unauthorized access or disclosure. However, no system can be entirely secure. While we take measures to protect your information, we cannot guarantee that your data, searches, or other communications will always remain secure. You are responsible for all activity on the Protocol associated with Ethereum network addresses and/or other cryptocurrency wallets.
Age Limitations
As permitted by applicable law, we do not allow individuals under the legal age in their jurisdiction to use our Services or Sites. If you become aware that someone under the legal age has unlawfully provided us with personal data, please contact us at support@thepac.io. We will take appropriate steps to delete such information, close any associated accounts, and, where possible, prevent the user from continuing to access our Services.
Changes to This Policy
If we make any changes to this Policy, we will update the "Last Updated" date above. We encourage you to review this Policy periodically to stay informed. If we make material changes, we will notify you through additional means, such as via the email address associated with your account or through notifications on our Services or Sites.
Online Tracking Opt-out Guide
Like many online services, we use tracking technologies provided by Google and other companies. These services utilize technologies such as cookies and web beacons to collect information directly from your device, including details about your browsing activities, interactions with websites, and the device you use to connect to the internet. There are several ways to opt out of having your online activity and device data collected through these services, and we have summarized the options below:
Blocking Cookies in Your Browser: Most browsers allow you to remove or reject cookies, including those used for interest-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 view which cookies have been set on your device and how to manage or delete them, visit www.allaboutcookies.org
Blocking Advertising ID Use in Your Mobile Settings: Your mobile device settings may allow you to limit the use of the advertising ID associated with your 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 or by installing privacy plug-ins.
Platform Opt-outs: The following advertising partners offer opt-out features that allow you to opt out of the 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 provided by the following industry organizations to limit the use of your information for interest-based advertising by participating companies. Please note that these opt-out mechanisms are specific to the device or browser on which they are used, so you will need to opt out on each browser and device you use:
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org
Additional Disclosure for Our Consumers and Customers
This Additional Disclosure outlines our collection, use, and sharing of personal information provided by users to initiate or complete interactions with the Protocol. In the event of a conflict between this Additional Disclosure and other sections of the Privacy Policy, the terms of this Additional Disclosure will take precedence.The types of personal information we collect and share can include:
Contact details
Transaction history
Cryptocurrency balances and wallets
Even if you are no longer our customer, we may continue to share your information as described in this notice.
Reasons We Can Share Your Personal Information
We may share users' personal information to operate certain aspects of the Protocol and our business. Below is an overview of the reasons we share your personal information, whether we do so, and whether you can limit this sharing:
For our everyday business purposes: We share users' personal information to process and match orders, comply with court orders, and address legal investigations. You cannot limit our sharing of this information.
For our marketing purposes: We share users' personal information to offer our products and services to you. You cannot limit our sharing of this information.
For joint marketing with financial companies: We do not share users' personal information for joint marketing purposes.
For affiliates' everyday business purposes: We do not share users' personal information for affiliates' everyday business purposes.
For affiliates to market to you: We do not share users' personal information for our affiliates to market to you.
For nonaffiliates to market to you: We do not share users' personal information for nonaffiliates to market with you.
Here are the definitions mentioned above:
Affiliates: Companies related by common ownership or control.
Nonaffiliates: Companies not related by common ownership or control.
Joint marketing: A formal agreement between nonaffiliated financial companies to jointly market financial products or services to you.
How Does the PAC Protect My Personal Information?
We implement security measures in compliance with applicable laws to protect your personal information from unauthorized access and use. These measures include advanced computer safeguards, secure file storage, and restricted access to physical locations.
How Does the PAC Collect My Personal Information?
We collect your personal information in various ways, including: (a)when you deposit digital assets into the Protocol; (b)when you make transactions using the Protocol; (c)when you withdraw digital assets from the Protocol. Additionally, we may collect your personal information from other companies as permitted by law.
Contact Us
If you have any questions about this Policy or wish to exercise your statutory rights, please reach out to us. We will respond within a reasonable timeframe, subject to applicable laws. You can contact us at support@thepac.io
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