For the purposes of EU data protection laws ("Data Protection Legislation"), HBAR Foundation is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).
1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
The categories of information we collect can include:
Information you provide to us directly. We may collect personal information, such as your name, phone number, location, date of birth, occupation, payment information, driver’s license/photo ID, social media accounts, and email address when you use our Site, submit a grant application, sign up for our mailing list, enter a contest or sweepstakes, or otherwise communicate with us. We may also collect any communications between you and HBAR Foundation and any other information you provide to HBAR Foundation, including without limitation, information about your interests, such as your interests in developing and/or launching a distributed application, interests in learning about hosting and running a node, and/or interest in becoming a system integration partner. Additionally, if you intend to receive tokens from us or otherwise enter into a contractual relationship with us, you will be asked to provide us or our third party service providers with the following information in order to meet our know-your-customer (KYC) and anti-money laundering (AML) checks: name, email, address, date of birth, phone number, copies of driver’s license or passport, and any other information necessary to confirm your status (collectively, “Verification Information”). This Verification Information will be used to screen you against Office of Foreign Assets Control (OFAC) watch lists as well as gather information about you for Bank Secrecy Act (BSA) compliance purposes.
Data collected through the use of the Site. We may collect information about how you use the Site, your actions on the Site, and content you post to the Site, and any content you provide through other functionalities on the Site (“User Content”). Please remember that HBAR Foundation may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Site, you consent to the recording, storage, and disclosure of such communications you send or receive for these purposes.
Information we receive from third parties. From time to time, we may receive information about you from third parties, such as our service providers. We may also collect information about you that is publicly available.
We use this information to operate, maintain, and provide to you the features and functionality of the Site, as well as to communicate directly with you, such as to send you email messages. We may also send you Site-related emails or messages (e.g., account verification, updates to features of the Site, technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.
Legal Basis for processing in the EU
If you are a resident in the EU, we need to tell you the legal basis on which we collect and use your personal information. Please note that we will use the following such legal basis:
The provision of personal information by you may be necessary for the performance of any contractual relationship we have with you; or
Where it is necessary for compliance with our legal obligations laid down by EU law; or
Where in our legitimate interests provided these are not overridden by your interests and fundamental rights and freedoms (this includes our own legitimate interests and those of other entities and branches in our group of companies) for the following purposes: (i) to contact you and respond to your requests and enquiries; (ii) for business administration, including statistical analysis; (iii) to personalize your visit to the Site; (iv) for fraud prevention and detection and to comply with applicable laws, regulations or codes of practices; and (v) in the case of Verification Information only, for the purpose of receiving tokens from us or otherwise interacting with the Site, including without limitation, to ensure that you meet our KYC and AML checks.
Additionally, our Site permits you to remove any and all personal data that you enter or upload into the Site or otherwise provide to us by submitting a delete request to the Site. If you withdraw your consent or remove your personal data from the Site and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Site.
In summary, we need certain categories of personal data in order to communicate with you via the Site or to make, or discuss making, a grant to you or your organization. Certain other personal data is processed for our legitimate interests in cases where this does not result in prejudice to you. Certain other personal data is processed based on consent.
We use or may use 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) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Site; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Site.
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. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. 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 performed certain functions with it.
3. SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We may share your personal information with:
Third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes;
Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing KYC and AML verification services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services;
Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
4. CONTROL OVER YOUR INFORMATION
User Information Settings. You may update the information that you have provided to us, such as your contact information, interests, and developer status by emailing us at firstname.lastname@example.org.
How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., changes/updates to features of the Site, technical and security notices).
Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at email@example.com.
5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website over time so that they may play or display ads on our Site, on other devices you may use, and on other websites, apps or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site and other information. We may also share a common account identifier (such as an email address or user ID) to help us identify you across devices. We and our third party partners use this information to research the market and/or make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. Some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookie, you may need to perform the opt-out task again. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Site on your browser or mobile device, lor otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Site and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
6. HOW WE STORE AND PROTECT YOUR INFORMATION
For individuals based in the EU, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under "What Information Do We Collect And For What Purpose?") and in accordance with our legal obligations and legitimate business interest, except if required otherwise by law.
Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Site. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
7. CHILDREN’S PRIVACY
HBAR Foundation does not knowingly collect or solicit any information from anyone under the age of 13 on this Site. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
8. LINKS TO OTHER WEB SITES AND SERVICES
The Site may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
9. EU PRIVACY RIGHTS
If you are located in the EU, you have the following rights in respect of your personal data that we hold:
a. Right of access. The right to obtain access to your personal data.
b. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
c. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
d. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
e. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
f. Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
10. HOW TO CONTACT US