Privacy Policy
Nilabs Privacy Policy
Last Updated: 25 January, 2024
This Privacy Policy is crafted to provide you with insights into how Nilabs, Inc. (“Nilabs”, “we”, “us,” or “our”) collects, utilizes, processes, and shares your personal information, and to empower you with an understanding of and the ability to exercise your privacy rights.
About Our Services and the Blockchain
Our Services (as defined below) may facilitate engagement with specific decentralized cryptographic protocols like blockchains, which we neither possess nor control (each, a “Protocol”). Our Services may also enable the establishment of a digital wallet through third-party services that are beyond our ownership and control, allowing you to take self-custody of and manage digital assets (such as NFTs, cryptocurrency, or blockchain tokens). This also empowers you to engage with third-party services and supported Protocols to facilitate the sale, purchase, trade, and distribution of digital assets on the decentralized blockchains where these digital assets are recorded (each, a “Blockchain”).
An Important Note Regarding Blockchain Technologies: Should you engage in our Services about the creation and management of digital assets, smart contracts will be utilized. These contracts inherently gather information, such as your digital wallet address (which may be deemed personal information in certain legal jurisdictions). This information will be stored on a public blockchain over which we have no control. A smart contract functions as computer code that autonomously processes events when predefined conditions are met; for instance, when a transaction is initiated to add a token to a digital wallet, a smart contract would automatically execute the proposed action. In such instances, your personal information, such as a digital wallet address, will be permanently recorded on that blockchain through the execution of a smart contract, and this personal information may be unalterable or irretrievable due to the immutable nature of the blockchain.
We strongly encourage you to thoroughly review our Terms of Service for comprehensive information, including specific terms and obligations pertaining to the utilization of our Services, which may encompass dispute resolution mechanisms.
SCOPE OF THIS PRIVACY POLICY
This Privacy Policy is applicable to the processing of personal information conducted by us, including within our websites and other offerings, whether online or offline. For ease of reference, our collective websites and offerings are collectively referred to as the “Services.”
An Important Clarification: It's important to note that this Privacy Policy does not pertain to the personal information we handle on behalf of our customers through their utilization of our Services (“Customer Data”). The governing policies for the collection and use of Customer Data are those established by our respective customers. Our handling of Customer Data is determined by the contractual agreements we have with our customers and not by the provisions of this Privacy Policy. Any inquiries or requests concerning Customer Data should be directed to the respective customer.
Modifications to Our Privacy Policy. We retain the right to amend this Privacy Policy at our discretion. Should substantial alterations be made to this Privacy Policy, we will provide notification as mandated by applicable law. By continuing to use our Services after the implementation of the updated Privacy Policy, you acknowledge and agree to be bound by its terms.
PERSONAL INFORMATION WE COLLECT
The types of personal information we collect are contingent upon your interactions with us, our Services, and the stipulations of applicable laws. We collect information that you furnish directly to us, data we automatically obtain when you employ our Services, and information from external sources like third-party services and organizations, as delineated below.
A. Personal Information Voluntarily Provided by You
We may gather personal information that you choose to share with us.
◉ Account Establishment.
When you create an account, we may collect personal information such as your name, email address, digital wallet address, and more.
◉ Online Transactional Data.
Information related to your wallet address and details associated with your transactions, including but not limited to transaction specifics, transaction purposes, details of fund sources, senders and recipients of funds, and ultimate beneficiary information, may be collected.
◉Communications with Us.
When you seek information about our Services, sign up for our newsletter, request customer or technical support, or engage in other forms of communication with us, we may collect personal information like your email address, digital wallet address, or online alias (e.g., Discord handle). Surveys. We may invite you to participate in surveys, and if you opt to participate, we may collect personal information from you as part of the survey.
◉ Interactive Features.
Both we and other users of our Services may collect personal information that you submit or make available through our interactive features, such as blockchain interactions, messaging and chat features, comment sections, forums, blogs, and social media pages. Information shared using the public sharing features of our Services may be considered as "public" unless otherwise mandated by applicable law, and it may not be subject to the privacy safeguards outlined herein.
◉ Sweepstakes or Contests.
We may collect personal information that you provide when participating in any sweepstakes or contests that we organize. In certain jurisdictions, we may be required to publicly disclose information about the winners of sweepstakes and contests.
◉ Conferences, Trade Shows, and Other Events.
When we attend or host conferences, trade shows, and similar events, we may collect personal information from individuals in attendance.
◉ Business Development and Strategic Partnerships.
We may gather personal information from individuals and third parties in connection with evaluating and pursuing potential business opportunities.
◉ Job Applications.
Job openings and employment opportunities may be posted on our Services. If you respond to any of these postings, we may collect personal information, including your job application, CV, cover letter, and any other details you provide to us.
B. Collection of Personal Information Automatically
When you utilize our Services, personal information may be collected automatically.
Automatic Gathering of Personal Information.
As you engage with our Services, certain information may be automatically collected, including your Internet Protocol (IP) address, user preferences, MAC address, cookie identifiers, mobile carrier, mobile advertising identifiers, and other unique identification markers, as well as browser or device details, location data (including an approximate location determined from your IP address), and your internet service provider. Additionally, we may automatically collect data related to your interactions with our Services, such as the webpages you visit before, during, and after using our Services, details about the links you click on, the types of content you engage with, the frequency and duration of your activities, and other information about your usage patterns.
Cookie Policy (and Other Technologies).
We, along with third parties providing content, advertisements, or additional functionalities on our Services, may employ technologies like cookies, pixel tags, and other similar mechanisms (“Technologies”) to automatically gather information as you utilize our Services. Cookies. Cookies are tiny text files stored in your device's web browser, serving to store preferences and enhance your overall experience. Pixel Tags/Web Beacons. A pixel tag, also referred to as a web beacon, is a snippet of code embedded within our Services to track user engagement. The use of pixel tags enables us to record, for example, when a user visits a specific webpage or interacts with a particular advertisement. Additionally, we may include web beacons in emails to determine whether messages have been opened, acted upon, or forwarded. Our utilization of these Technologies generally falls into the following categories:
Operationally Necessary: This encompasses Technologies that grant you access to our Services, applications, and tools essential for identifying irregular website behavior, preventing fraudulent activities, enhancing security, or enabling the use of our features.
Performance-Related: Technologies may be used to evaluate the performance of our Services, including within our analytical practices to gain insights into how individuals engage with our Services (refer to Analytics below).
Functionality-Related: We may employ Technologies that enable us to offer improved functionality while accessing or using our Services. This may involve recognizing you when you sign into our Services or tracking your specified preferences, interests, or previously viewed items.
Advertising- or Targeting-Related: Both first-party and third-party Technologies could be used to deliver content, including advertisements tailored to your interests, on our Services or on third-party digital platforms.
To learn about your options concerning these Technologies, please refer to the section titled "Your Privacy Choices and Rights" below.
◉ Analytics. In processing analytics information on our Services, we may employ Technologies and other tools provided by third parties. These Technologies aid us in gaining a better understanding of how our digital Services are used, enabling continuous improvement and personalization. Some of our analytics collaborators include:
◉ Google Analytics. For more details on how Google utilizes your personal information (including for its own purposes, such as profiling or linking it with other data), please consult Google Analytics' Privacy Policy. To find out more about opting out of Google Analytics' utilization of your information, please click here.
C. Personal Information Obtained from Alternate Sources
Third-Party Services and External Origins. We may acquire personal information pertaining to you from alternative origins, including third-party services and external entities. For instance, if you access our Services through a third-party application, such as a third-party login service or a social media platform, we may gather personal information linked to you from that particular third-party application, as per the privacy settings you have configured.
Blockchain Data. We may acquire personal information pertaining to you through our examination of blockchain data.
HOW WE UTILIZE YOUR PERSONAL INFORMATION
We make use of your personal information for a variety of business objectives, encompassing the provision of our Services, administrative functions, and the promotion of our products and Services, as elaborated below.
A. Provision of Our Services
We employ your information to fulfill our contractual obligations to you and furnish you with our Services, which includes:
Administering your data and accounts;
Facilitating transactions you engage in; Granting access to specific sections, functionalities, and features of our Services;
Addressing inquiries concerning customer or technical support;
Conveying communications regarding your account, undertakings on our Services, and alterations to policies;
Processing payment methods for acquired products or Services;
Processing applications if you apply for a position we advertise on our Services;
and Enabling your registration for events.
B. Administrative Objectives
We make use of your information for various administrative purposes, which encompass: Pursuing our legitimate interests, such as:
Direct marketing, research and development (comprising marketing research), network and information security, and the prevention of fraud;
Detecting security incidents, safeguarding against malicious, deceitful, fraudulent, or unlawful activities, and pursuing legal actions against those responsible for such activities;
Assessing interest and engagement in our Services;
Enhancing, enhancing, or enriching our Services;
Developing novel products and services;
Ensuring internal quality control and safety;
Validating and confirming individual identities, including handling requests to exercise your rights under this Privacy Policy;
Identifying and rectifying errors with our Services;
Conducting audits related to interactions, transactions, and other compliance activities;
Sharing personal information with third parties when necessary to furnish the Services;
Upholding our agreements and policies;
and Carrying out actions required to adhere to our legal responsibilities.
C. Promotion and Advertisement of Our Products and Services
We may utilize personal information to tailor and furnish you with content and advertisements, in compliance with applicable laws. These materials may be provided to you through channels such as email campaigns or custom audience advertising.
If you have any inquiries regarding our marketing practices, you are welcome to reach out to us at your convenience, as outlined in the "Contact Us" section below.
D. Other Objectives
Furthermore, we employ your personal information for other purposes, either as requested by you or as allowed by applicable legislation.
With Your Explicit Consent, we may use personal information for additional objectives explicitly disclosed to you at the time of data provision or with your consent.
De-identified and Aggregated Data. Personal information may also be employed to generate de-identified and/or aggregated data, encompassing demographic information, details regarding the device you use to access our Services, or other analytical insights we produce.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We share your personal information with third parties for various business purposes, encompassing the provision of our Services, safeguarding our interests and those of others, or in significant business transactions like mergers, sales, or asset transfers, as detailed below.
A. Sharing to Facilitate Our Services Blockchain Usage Notice:
Some aspects of our Services may operate on or interact with blockchain technology. When you use parts of our Services linked to or interacting with the blockchain, your interactions and transaction information may be shared with the relevant blockchain network, potentially accessible to third parties due to the blockchain protocol's inherent nature.
The categories outlining third parties with whom we may share your personal information are explained below:
Service Providers: We may share your personal information with third-party service providers and vendors who assist us in delivering our Services. This includes providers and vendors offering IT support, hosting, payment processing, customer service, and related services.
Business Partners: Your personal information may be shared with business partners to fulfill product or service requests you make. We may also share your personal information with business partners with whom we jointly offer products or services.
Affiliates: We may share your personal information with affiliated entities within Nilabs.
Interaction with Other Users or Third Parties: As described in the "Personal Information We Collect" section, our Services may enable you to share personal information or interact with third parties, including individuals and entities not using our Services, as well as the general public (e.g., those on the blockchain).
Advertising Partners: Your personal information may be shared with third-party advertising partners. These partners may employ Technologies and tracking tools on our Services to gather information about your activities and device (e.g., IP address, cookie identifiers, pages visited, location, time of day). This information may be used to deliver personalized advertisements to you when you visit digital properties within their networks, often referred to as "interest-based advertising," "targeted advertising," "personalized advertising," or "cross-context behavioral advertising."
APIs/SDKs: In the course of our Services' functionality, we may use third-party application program interfaces ("APIs") and software development kits ("SDKs"). SDKs typically collect your mobile device identifier and information related to your use of the Services, enabling third parties, including analytics and advertising partners, to collect your information for various purposes, such as providing analytics services and personalized advertising. For additional information regarding our use of APIs and SDKs, please contact us using the information provided in the "Contact Us" section below.
B. Sharing to Protect Us or Others
We may access, retain, and disclose stored information associated with you to external parties if we have a bona fide belief that doing so is necessary or appropriate to: comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas; 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 activities.
C. Sharing in the Event of Merger, Sale, or Other Asset Transfers
In cases where 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 information may be sold or transferred as part of such a transaction, in accordance with applicable laws and contractual agreements.
Your Privacy Choices. Your options concerning the use of your personal information are subject to applicable laws and are detailed below.
Email Communications: If you receive unwanted emails from us, you can utilize the unsubscribe link located at the email's bottom to opt out of future email communications. Please note that transaction-related emails regarding products or Services you have requested will continue. Additionally, certain non-promotional communications regarding us and our Services will remain unaltered, and you will be unable to opt out of such communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
"Do Not Track": "Do Not Track" ("DNT") is a privacy preference that users can activate in specific web browsers. It is important to note that we do not respond to or adhere to DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Personalized Advertising: You can adjust your browser or device preferences to halt or restrict the placement of Technologies on your device, or remove them as permitted by your browser or device settings. Modifying your preferences may impact the proper functionality of our Services. Please be aware that cookie-based opt-outs do not apply to mobile applications. Nevertheless, you can opt out of personalized advertisements on some mobile applications by following provided instructions for Android, iOS, and other platforms.
The online advertising industry also offers websites where you can opt out of receiving targeted ads from data partners and other advertising partners who participate in self-regulatory programs. You can access these websites and obtain more information about targeted advertising, consumer choice, and privacy by visiting entities such as the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note that you must separately opt out for each browser and device.
Your Privacy Rights: In accordance with applicable laws, you may have the following rights:
Confirm Whether We Are Processing Your Personal Information (the right to know).
Access and Portability of Your Personal Information, including the right to obtain access to or a copy of your personal information, as well as receiving an electronic copy of personal information you have provided to us, or requesting that we transmit that information to another company in a structured, commonly used, and machine-readable format (referred to as the "right of data portability").
Request Correction of your personal information if it is inaccurate or incomplete.
Request Deletion of your personal information.
Request to Opt-Out of Specific Processing Activities, including, where applicable, processing of your personal information for "targeted advertising" (as defined by relevant privacy laws), "selling" of your personal information (as "sell" is defined by applicable privacy laws), or engaging in "profiling" for certain decisions with significant legal or similar effects on you (as defined by relevant privacy laws).
Request Restriction of or Object to our processing of your personal information.
Withdraw your Consent to our processing of your personal information. It is important to note that your withdrawal will only be effective for future processing and will not affect the lawfulness of processing conducted before the withdrawal.
If you wish to exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will process such requests in accordance with applicable laws.
If applicable laws grant you the right to appeal our decision regarding your request, you may do so by informing us and providing information supporting your appeal.
INTERNATIONAL DATA TRANSFERS
All data processed by Nilabs may be moved, processed, and stored worldwide, including, but not limited to, the United States or other countries, which may have varying data protection laws compared to your place of residence. We are committed to safeguarding your information in compliance with applicable legal requirements.
When Nilabs transfers personal information originating from the European Economic Area, Switzerland, and/or the United Kingdom to a country lacking an adequate level of data protection under prevailing data protection laws, one of the safeguards we may employ to facilitate such transfers is the utilization of EU Standard Contractual Clauses.
For more details concerning the safeguards we implement for international transfers of your personal information, please contact us using the information provided below.
RETENTION OF PERSONAL INFORMATION
Nilabs retains the personal information collected as outlined in this Privacy Policy for the duration of your use of our Services or as necessary to fulfill the purposes for which it was collected. This includes providing our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business objectives, enforcing our agreements, and complying with relevant laws.
To ascertain the appropriate retention period for personal information, we consider factors such as applicable legal obligations, the quantity, nature, and sensitivity of the personal information, associated risk factors, the purposes for processing your personal information, and whether those purposes can be achieved through alternative means.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
California Shine the Light: The California "Shine the Light" law allows California residents to request, once a year and free of charge, a list of third parties to whom we may have disclosed their personal information (if any) for direct marketing purposes in the previous calendar year. Additionally, this list includes the type of personal information shared with those parties.
If you are a California resident and wish to exercise your California rights, please contact us as detailed in the "Contact Us" section below. We will handle such requests in accordance with applicable laws.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
Nevada residents have the right to opt-out of the sale of specific personal information to third parties who intend to license or sell that personal information. Please note that we do not currently engage in the sale of your personal information, as defined in Nevada Revised Statutes Chapter 603A. If you have any inquiries, please contact us as provided in the "Contact Us" section below.
CHILDREN’S INFORMATION
Our Services are not directed at children under the age of 13 (or any other age mandated by local law), and we do not knowingly collect personal information from minors.
If you are a parent or guardian who believes that your child has provided personal information to our platform without your consent, or if you wish to review, modify, or delete information collected from your child (if applicable), you can contact us as specified in the "Contact Us" section below. In the event that we become aware of a child providing us with personal information in violation of applicable law, we will promptly delete the collected information, unless there exists a legal obligation requiring its retention.
OTHER PROVISIONS, INCLUDING FOR EU/UK CITIZENS
Sensitive Personal Information: Nilabs typically does not require you to disclose sensitive personal information (such as details regarding race, religious beliefs, sexual orientation, or trade union membership). However, if you voluntarily provide us with sensitive personal information for any reason, you consent to Nilabs collecting, using, and disclosing that information for the purpose for which it was shared with us.
Third-Party Websites/Applications/Services: Our Services may include links to other websites/applications, and other websites/applications may reference or link to our Services. The Services may also enable you to interact with third-party services. These third-party services are not under Nilabs' control. We encourage our users to review the privacy policies of each website and application they engage with. Nilabs does not endorse, monitor, or approve these third parties and is not responsible for their actions or omissions, including their privacy practices, content, or software errors or bugs. Providing personal information to third-party websites or applications is at your own discretion.
Our Lawful Basis for Processing Personal Information: If your personal information falls under the jurisdiction of the EU General Data Protection Regulation or related legislation, Nilabs' processing of your personal information may be supported by the following legal bases:
| Lawful Basis: Performance of a Contract (i.e., to Provide Our Services to You) | Lawful Basis: Legitimate Interest | Lawful Basis: Consent | Lawful Basis: For Compliance with Legal Obligations | |
|---|---|---|---|---|
To Provide the Services or Information Requested | ✔ | ✔ | ✔ | |
To Measure Performance and Carry Out Research | ✔ | ✔ | ||
For Customer Support | ✔ | ✔ | ✔ | ✔ |
For Advertising Purposes | ✔ | ✔ | ||
For Administrative or Legal Purposes | ✔ | ✔ | ✔ |
Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to complain with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.
CONTACT US
Nilabs is the controller of the personal information we process under this Privacy Policy.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Nilabs, Inc.
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