Last Updated: 12 November 2021
Personal data means data that may allow us or any third party (whether commercial or governmental) to identify you (whether on its own, or in connection with other data). It includes but is not limited to your name, your IP address, your wallet ID, your browsing habits, your geolocation, your tax ID, your credit card number, your passport number and your driver's licence number.
- PERSONAL INFORMATION WE COLLECT
The categories of personal data we collect depend on how you interact with us, the Services, and the requirements of applicable law. We collect, process and transfer personal data that you provide to us, as well as personal data we obtain automatically when you use the Services, and personal data from other sources such as third-party services and organizations, as described below.
- Information You Provide to Us Directly
We may collect the following personal data that you provide to us.
- Account Creation. We may collect information when you create an account using the Services, such as your name, email address, and username.
- Purchases. We may collect personal data and details associated with your purchases, including payment data. Any payments made via the Services are processed by third-party payment processors. We do not directly collect or store any payment card data entered through the Services, but we may receive data associated with your payment card data (e.g., your billing details).
- Your Communications with Us. We may collect personal data such as email address, phone number, or mailing address when you request data about the Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain data which may include personal data.
- Interactive Features. We and others who use the Services may collect personal data that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any personal data you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and may not be subject to the privacy protections referenced herein. Please exercise caution before revealing any personal data that may identify you to other users.
- Sweepstakes or Contests. We may collect personal data you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share personal data of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal data from you when you attend conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal data from you and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities relevant to the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your personal data to assess your qualifications.
- Information Collected Automatically
We may collect personal data automatically when you use the Services:
- Automatic Data Collection. We may collect certain personal data automatically when you use the Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect personal data regarding your use of the Services, such as pages that you visit before, during and after using the Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use the Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to the Services, applications, and tools that are required to identify irregular website behavior, prevent illicit and fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of the Services, including as part of our analytic practices to help us understand how individuals use the Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using the Services. This may include identifying you when you sign into the Services or keeping track of your specified preferences, interests, or past items viewed;
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics data on the Services. Some of our analytics partners include:
- Information Collected from Other Sources
We may obtain personal data about you from other sources, including through third-party services and organizations. For example, if you access the Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal data about you from that third-party application that you have made available via your privacy settings.
- HOW WE USE YOUR INFORMATION
We use your personal data for a variety of purposes, including to provide the Services, for administrative purposes, and to market the Services, as described below.
- Provide Our Services
We use your personal data to fulfil our contract with you and provide you with the Services, such as:
- Managing your personal data and accounts;
- Providing access to certain areas, functionalities, and features of the Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on the Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job we post the Services; and
- Allowing you to register for events.
- Administrative and Compliance Purposes
We use your personal data for various administrative and compliance purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Surveillance and detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity (and assisting law enforcement with such prosecution);
- Measuring interest and engagement in our Services;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Complying with legal, tax or regulatory enquiries or investigations including assisting law enforcement and other governmental departments or agencies by filing suspicious activity reports and sharing personal data to support a tax, regulatory, legal or criminal investigation;
- Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Managing our risk and operations;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
- Marketing our Products and Services
We may use personal data to provide you with tailored content, such as through email campaigns. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal data for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
- Other Purposes
We also use your personal data for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal data for other purposes that are clearly disclosed to you at the time you provide personal data or with your consent.
- De-identified and Aggregated Information. We may use personal data and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access the Services, or other analyses we create.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide data about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague. Please only share with us contact data of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker) and who have consented to you sharing such content.
- HOW WE DISCLOSE YOUR INFORMATION
We disclose your personal data to third parties for a variety of purposes, including to provide the Services, to protect us or others, to support law enforcement or government authorities (wherever situated) or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide our Services
The categories of third parties with whom we may share your personal data are described below.
- Service Providers. We may share your personal data with third-party service providers who use that data to help provide the Services. This includes service providers that provide the HUMAN Protocol with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal data with partners to provide you with a product or service you have requested. We may also share your personal data to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal data with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
- Governmental departments and agencies, including law enforcement (including but not limited to those in the Cayman Islands who may in turn share your personal data)
- Disclosures to Protect Us or Others
We may access, preserve, and disclose any personal data we store associated with you to external parties (including government agencies and authorities, whether in the Cayman Islands or in other jurisdictions) if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your personal data may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
- YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal data are determined by applicable law and are described below.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications, and you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to (and under Cayman Islands law, you do have the right to all of the following (except the right of portability)):
- Access Personal Information
- about you, including: (i) confirming whether we are processing your personal data; (ii) obtaining access to or a copy of your personal data in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal data that you have provided to us, or asking us to send that data to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
- Request Correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data;
- Request Deletion of your personal data;
- Request Restriction of or Object to our processing of your personal data; and
- Withdraw your Consent to our processing of your personal data.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
- SECURITY OF YOUR INFORMATION
By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
- INTERNATIONAL DATA TRANSFERS
All personal data processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We shall safeguard your personal data consistent with the requirements of applicable laws.
If we transfer personal data to countries outside the Cayman Islands (unless such transfer is to the UK or the European Economic Area), we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.
- RETENTION OF PERSONAL INFORMATION
- CHILDREN’S INFORMATION
The Services are not directed to persons under 18 (or other age as required by local law), and we do not knowingly collect personal data from children.
If you are a parent or guardian and believe your child has provided personal data to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal data in violation of applicable law, we will delete any personal data we have collected, unless we have a legal obligation to keep it.
- OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to the Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal data to third-party websites or applications is at your own risk.
Supervisory Authority. Certain jurisdictions give you rights to lodge a complaint with your local data protection supervisory authority for example if you believe your personal data has been unfairly processed. Without limitation, if you are located in the Cayman Islands, the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law. If you are unsure of your rights, you should seek advice.
- CONTACT US
4th Floor, Apollo House East, 87 Mary St, George Town KY1-1107