GenLayer Foundation (“we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:
Collectively, we refer to these interactions as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services could collect Personal Information, including:
With your consent, we and our service providers collect Personal Information in a variety of ways, including:
Through the Services.
We collect Personal Information through the Services, for example, when you register an account to access the Services, connect your wallet, complete a survey, contact customer support or take part in governance votes.
From Other Sources.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority, consent to do so and hereby allow us to use the information in accordance with this Privacy Policy.
Further to your consent, we and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our marketing materials and facilitating social sharing.
We will engage in this activity with your prior consent, where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services.
We will provide personalized services based on our legitimate interests, and with your prior consent to the extent required by applicable law.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
In order to provide you with an optimal experience on our site, and provide you with the best services, we also use the services of third party partners. It is specified that we are not affiliated with third-party companies and cannot be held responsible for them. Therefore, we invite you to consult the data protection policies used by our partners which may include:
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Further to your consent, Services could collect Other Information such as: Browser and device information, Information collected through cookies, pixel tags and other technologies, Demographic information and other information provided by you that does not reveal your specific identity, Information that has been aggregated in a manner such that it no longer reveals your specific identity.
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, mouse clicks, page scrolls, keystrokes, and other traffic data. Upon your consent, we and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.
The management of cookies depends entirely on your choice of settings on your terminal. You can use the Cookie Notice tool, available in the settings of your browser software, to choose to accept or refuse the recording of non-essential cookies on your terminal at any time. The configuration of each navigation software is different. It is generally described in the help menu of your navigation software.
We therefore invite you to read it to find out how to modify your settings depending on your browser:
You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
Pixel tags and other similar technologies.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us.
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the unsubscribe link in such email.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
We retain Personal Information for as long as needed or legally permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information could be transferred to countries outside of your country of residence, including the United States (pursuant to Adequacy Decisions), which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these “specified countries” is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. The UK recognizes the EEA and the specified countries as providing an adequate level of data protection according to UK standards. For transfers from the EEA or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of European Economic Area (EEA) data protection authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en. Information regarding the UK data protection authority is available here:
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.
Collection and Disclosure of Personal Information
The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
Categories of Personal Information
Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as username, contact information, government-issued ID, IP address and other online identifiers
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
Personal information as defined in the California customer records law, such as name, contact information and government-issued ID
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
Commercial Information, such as transaction information and purchase history
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
Internet or network activity information, such as interactions with our online properties
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
Geolocation Data, such as approximate location derived from IP address
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
Audio/Video Data. Audio, electronic, and similar information
Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities
We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months.
Sources of Personal Information
As described above, we collect these categories of Personal Information from you and from crypto wallet providers, when they share the information with us.
Use of Personal Information
As described above, we use these categories of Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including using Personal Information to:
Individual Rights and Requests
If you are a California resident, you may request that we:
To make a request for the disclosures or deletion described above, please contact us. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address or wallet address, in order to verify your identity (via email PIN confirmation) to protect against fraudulent requests. If you make a deletion request, we may ask you to confirm your request before we delete your Personal Information.
You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
Authorized Agents
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which may include:
If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
We are located at Quality Corporate Services Ltd., P.O. Box 712, Suite 102, Cannon Place, North Sound Road , George Town , Grand Cayman KY1-9006, Cayman Islands and are responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us through our website.