I. Our Collection and Use of Personal Information
Personal information collected from you
We may collect the following categories personal information submitted to us by individuals through the Services:
- Contact Information, including name, email address, social media handle, country or region and communication preferences. We use this information to fulfill your request, to communicate with you directly, and to send you communications in accordance with your preferences.
- Account Information, including username, email address, and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.
- Identity Verification Information. We may use identity verification services provided by third-party providers to verify your identity documents, confirm your identity and protect against fraud and abuse. When you create an account therein, you may be asked to submit your name, birthdate, address, phone number, email address, government identification number and copies of government identification documents, along with a selfie image. Our designated third-party identity verification provider(s) may use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match."
- Staking Information. If you choose to participate in Mina Foundation’s delegation program, or if you are the recipient of a grant, we may receive certain event-related information, including your public blockchain address associated with your self-hosted crypto wallet, crypto wallet type, and other transaction and event-related information. We may also require additional information from you in order to verify your identity and the transaction. Please note that in some cases we use third parties to assist us with the identity verification process. In these cases, you will provide your information directly to such third-party providers and will be subject to terms and conditions of such third-party providers.
- Event, Meeting, and Webcast Information, including registration information, and contact information. In some instances, we may also record audio and/or video from our meetings and events. We use this information to administer and facilitate the Services. We may also feature video clips or screenshots on websites.
- Inquiry and Communications Information, including information provided in custom messages sent through the forms, to one of our email addresses, or via phone. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the Services.
- Program Information, including information provided to participate in one of our programs, or to apply for a grant, such as your name, email address, and any other information you choose to provide to us, such as information regarding your proposal. If you apply for a program on behalf of a business, we may also collect information about the business, such as company name, place of registration and operation, beneficiary owner(s), and license information.
- Newsletter and Marketing Emails Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
- Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
information from third parties
We also obtain personal information from third parties. We may receive the same categories of personal information as described above from the following third parties:
- Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services.
- Social Media: When an individual interacts with our Services through various social media networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages.
- Service Providers: Our service providers that perform services solely on our behalf, collect personal information and often share information with us. The information may include name, residential address, contact information, demographic information, and information about your communications and related activities. We may use this information to administer and facilitate our services and programs, our communications with you.
- Ecosystem Partners: We may receive your information from our ecosystem partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our Services.
- Information from Other Sources: We may also collect information about individuals that we do not otherwise have from, for example, publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. Such information may include contact information, social media account information, general location, domains, cryptocurrency wallet address and related information, the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information (including cryptocurrency assets), and interest-in-services information, employment-related information, and interest-in-services information. We may combine this information with the information we collect from an individual directly. We use this information to provide the Services, contact individuals, to process employment applications and job applicant screening, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.
additional uses of personal information
We may use personal information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested;
- Manage our day-to-day operations;
- Verify your identity and entitlement to Services;
- Register you for and provide you access to events and webcasts;
- Communicate with individuals, including via email and social media;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- For marketing and advertising purposes, including to market to you or offer you through email information and updates we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Comply with contractual and legal obligations and requirements;
- Fulfill any other purpose for which you provide personal information; and
- For any other lawful purpose, or other purpose that you consent to.
We may collect information you provide to us and information about how you access and use the Services when you visit our sites, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Such information may include, but is not limited to
- Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
- Information about the way you access and use our Services, for example, the site from which you came and the site to which you are going when you leave our services, whether you open emails or click the links contained in emails, and other browsing behavior and actions you take on the Sites.
- Information about how you use the Services, such as the pages you visit, the links you click, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing.
- Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
- Analytics information. We may collect analytics data or use third-party analytics tools to help us measure traffic and allow us to improve your customer experience.
All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) identify you across multiple devices; © provide and monitor the effectiveness of our services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and perform certain functions with it.
III. Our Disclosure of Personal Information
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
- Foundation Entities: We may share personal information with other companies owned by or under common ownership as Mina Foundation, Inc., which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
- Blockchain Participants: Holdings and transactions associated with your crypto wallet address are publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public. Through the use of the Services, we display blockchain information and other data associated with the recipient transaction wallet.
- Marketing Providers: We coordinate and share personal information with marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf.
- Other Users: If you participate in one of our online communities or forums, we may disclose your account username to other users, as well as any other information you choose to provide and make public.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.
IV. Control Over Your Information
You may control your information in the following ways:
- Email Communications Preferences. You can stop receiving email communications from us by clicking on the “unsubscribe” link provided in communications. You may not opt-out of service-related communications.
- Modifying or Deleting Your Information. You have the right to inform us not to process your information. You may do so by checking or unchecking boxes on the forms when we collect such information. In addition, if you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
V. Data Retention
We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire.
To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Once retention of the personal information is no longer necessary for the purposes outlined above, we will delete the personal information or, if this is not possible, then we will securely store the personal information and isolate it from further processing until deletion is possible.
VI. Children's Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at firstname.lastname@example.org. If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).
VII. Links to Third-Party Websites or Services
IX. Contact Us
X. California Privacy Notice
The California Consumer Privacy Act (“CCPA”) affords residents certain rights with respect to their personal information. If you are a California Resident, please refer to this section for additional California-specific privacy information.
As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law). You have the right to (i) request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity; (ii) request the deletion of personal information we have collected from you, subject to certain exceptions; (iii) request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of the user’s personal information. (iv) direct us not to sell or share personal information we have collected about you to third parties now or in the future. (v) not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you services or engage with you in the same manner. California residents that have an established business relationship with us have the right to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).
HOW TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS
Please submit a request by emailing us at email@example.com with the subject line, “California Rights Request”;
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your residence, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last interaction with our Services.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf.
For requests to know, delete, or correct personal information, we require the following for verification purposes:
- a power of attorney valid under the laws of California from you or your authorized agent; or
- sufficient evidence to show that you have:
- provided the authorized agent signed permission to act on your behalf; and
- verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.