- What information is covered under this policy?
- How personal information is collected
- “Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For the purposes of this Privacy Policy, there is no meaningful distinction between the terms “personal information” and “personal data”.
- You may choose not to provide some of the personal information described above. Please note, however, that some of our services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular service or feature of that service, you may not be able to use that service or feature.
- We may collect your personal information directly from our contact with you. This may include by you completing forms or parts of our website, Social Media, and/or other software and/or mobile applications, by you providing us with consent to access personal information such as photographs, videos or photo albums, by you providing us with consent to access the microphone and/or camera on your device, or by you contacting us via the email, telephone, through Social Media and other similar functions either directly through our website or through third party host websites, in person, through various marketing channels or competitions either directly through our website or through third party host websites, and surveys.
- You understand that any personal information that you provide to us must be accurate and up to date. We will assume this to be the case.
- In this Privacy Policy “Social Media” means social media networking sites of any kind or nature including but not limited to web or internet based or mobile telephonic devices or medium such as Facebook, Twitter, Instagram and LinkedIn which enable the creation and exchange of user generated content.
- Our website, Social Media, and/or other software and/or mobile applications may automatically collect the following information about you each time you visit or otherwise use our website, Social Media, and/or other software and/or mobile applications:
- technical information including but not limited to the Internet Protocol Address used to connect your device to the internet, the internet browser and version that you are using when accessing our website, Social Media, or other software and/or mobile applications, any additional plug-ins that you are using, and your device’s operating system and platform;
- information about the time and date you accessed our website, Social Media, or other software and/or mobile applications, and what you accessed on our website, Social Media, or other software and/or mobile applications. This includes links that you clicked on, what content you accessed, how long you accessed that content for, whether you downloaded or bookmarked any content, whether supplied by us or downloaded from a third party host, and how you navigated to and from our website, Social Media, or other software and/or mobile applications to other sites, apps or other pages hosted by us;
- details about the computer, device, hardware, or software used to access our services, such as IP address, device identifiers, internet service provider, plugins, device make and model, operating system, browser type, and other system specifications; and
- general location of your device derived from your IP address, crash logs, diagnostics, app interactions and other app performance data.
- blockchain wallet addresses, on-chain transaction hashes and related analytics
- We use technologies like cookies, log files, and web beacons to collect this information. These tools help us and our service providers recognize your device, manage authentication, remember preferences, personalize experiences, manage advertising, and conduct data analytics.
- We may collect personal information from Metabyte Labs, Inc. (“Affiliate”) and other third parties. We may obtain information about you, such as basic customer information, transaction information and product usage information, from our Affiliates as a normal part of conducting business.
- From public databases, we may obtain information about you, such as the United Nations Sanctions List, US ITA Consolidated Screening List, and the SEC EDGAR, including your name, address, email address, phone number, gender, national ID number and nationality/country of residence, date of birth, job role, public employment profile, listing on any sanctions lists maintained by public authorities, and other data as necessary.
- From public blockchain data, we may analyse timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses.
- From analytics providers, we may receive information about your Site usage, interactions, age group, and survey responses (including prior to account creation, in some cases).
- From retail merchants, the merchant may provide us with data about you, such as your name and contact details, and your transaction with that merchant.
- How we use your personal information
- Our use of, and transfer to any other application of, information received from Google APIs will adhere to the terms outlined in Google’s API Services User Data Policy, including the Limited Use requirements.
- You consent to the disclosure of your personal information to any of our related entities.
- You consent to our collection of your personal information and disclosing it to third parties where necessary and for the purposes for which it was collected.
- This may include:
- providing our services;
- investigating and/or preventing suspected fraud or other criminal activities or misuse of our services;
- where we collect or disclose information that is or relates to the Internet Protocol Address used to connect your device to the internet, for the purpose of fraud detection and management of the integrity of the services. This may include detecting when users who engage in illegal activities or breach our Terms of Use;
- where information is or relates to system version information of your device, or the make and model of your device, for the purpose of our compatibility assessments with our software versions and other aspects of our services;
- operating Full Sail;
- using your personal information to provide you with information that you have requested from us, although we do not create a link between your user ID and your user email;
- communicate with you, including to inform you of updates to the website, our Terms of Use and/or this Privacy Policy;
- using your personal information for marketing purposes to provide or offer services to you. This includes, but is not limited to, keeping you up to date with our latest news, events, special offers and promotion of our brand or other similar products that we think that you may be interested in. This includes both our direct marketing to you or another third party whom you have authorized us to disclose your personal information to;
- notifying you about any changes to our products, website, and/or other software and/or mobile applications, brand or services offered;
- seeking your opinion and feedback on any of our services, including for the purposes of product improvement and customization, website/software improvement and personalization and other general services;
- for consumer engagement and/or customer service purposes, including but not limited to identifying the effectiveness of advertising, allowing you to participate on website viral features such as sharing website content and other community features (for example, blogs);
- analyzing the usage of, and improve our services;
- for other general services such as website/software security, maintenance, identification of fraud or errors, internal accounting and administration, and for any other purpose that we are required or permitted to do by law; and
- managing our relationships with you and our other customers.
- For administrative and legal purposes, such as for compliance purposes. This includes enforcing our Terms of Use or enforcing or defending other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency, and to comply with our legal obligations and internal policies as permitted by law, such as preventing the Services to be accessed by individuals in sanctioned territories, or by sanctioned individuals.
- For safety, security and integrity focused on investigating in good faith alleged violations of our Terms of Use, including unauthorized access and use. In order to protect the Services, and ensure your continued access to the Services, your Personal Information is collected to prevent malicious actors from attacking and disrupting the Services.
- Who We Share Personal Information With
- In order to provide the Services, we must share your Personal Information in certain cases. This includes sharing your Personal Information with the Affiliates, with our Service Providers and the other third parties listed in this section. We do not sell your Personal Information.
- We may disclose Personal Information about you under the following circumstances:
- Group Entities. We may disclose Personal Information about you to our Full Sail affiliates and subsidiaries, if any, for the purpose of providing the Services and conducting business.
- Service Providers. We work with third parties for the purpose of providing the Services such as hosting, maintenance, network management, cybersecurity and support. These third parties may have access to or process your Personal Information as part of providing those services to us. For example:
- When you use a credit card to pay for our Services, information such as your name, billing address, phone number, email address and credit card information will be submitted to service providers for verification and to manage any recurring payments.
- We use cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you.
- We use service providers of business communication tools.
- We use service providers who manage the networks for the operation of the Services and to improve latency for our users.
- We use service providers to help us prevent malicious actors from threatening the Services and to comply with legal obligations, such as preventing individuals from sanctioned territories, or sanctioned individuals, from accessing the Services.
- Native Integrations. You can use native integrations to share data with other applications. Full Sail does not share data from integrated apps with any other services or clients.
- Legal. Personal information about you may be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Full Sail, our Users, a third party, or the public.
- Strategic Business Partners. Where you have provided your consent, we may share your Personal Information with our strategic business partners in limited circumstances, for example for marketing and advertising purposes.
- Your Rights
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- Your rights associated with the Services are described below. Please note these rights may only be available to you in specific regions, countries or states based on where you reside. In certain cases, we may be prevented from allowing you to exercise these rights but we will inform you if that is the case when you seek to exercise the rights.
- You have the following rights associated with the processing of your Personal Information:
- Your rights associated with the Services are described below. Please note these rights may only be available to you in specific regions, countries or states based on where you reside. In certain cases, we may be prevented from allowing you to exercise these rights but we will inform you if that is the case when you seek to exercise the rights.
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- Right to Access or Right to Know. You have the right to obtain access to the Personal Information we hold about you and to request certain information about our processing. You have the right to receive an explanation of:
- why we process your Personal Information;
- the categories of Personal Information we have about you;
- who we share your Personal Information with;
- how long we store your Personal Information; and
- who we received your Personal Information from if it was not collected from you directly.
- Right to Rectification or Correction. You have the right to correct, update or complete any Personal Information we hold about you that is inaccurate or incomplete. Please note that we may rectify or remove incomplete or inaccurate information, at any time and at our own discretion.
- Right to Erasure or Deletion. You may request to have your Personal Information anonymized, erased, or deleted, as appropriate. In this case, if there is no overriding legitimate interest or requirement to continue processing your Personal Information, we will erase your data.
- Right to Object to Processing. You have the right to object to our processing of your Personal Information where we are relying on a legitimate interest or if we are processing your Personal Information for direct marketing purposes.
- Right to Restrict Processing. You have a right in certain circumstances to stop us processing your Personal Information other than for storage purposes.
- Right to Portability. You have the right to receive, in a structured, commonly used, and machine-readable format, Personal Information that we hold about you, if we process it based on our contract with you, or with your consent, or to request that we transfer such Personal Information to a third party.
- Right to Withdraw Consent. You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdraw your consent.
- Right to Lodge a Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
- Right Against Discrimination. We will not discriminate against you for exercising your rights.
- Right to Opt Out of Targeted Advertising, Sale or Sharing. You can ask us to stop using your Personal Information for targeted advertising when required by law.
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- You may exercise these rights by contacting us as set out in the “Contact Us” section.
- Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights. Subject to certain restrictions, you can ask an agent to exercise your rights for you. If you have an agent exercising your rights, that person must provide to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor.
- To appeal any refusal by us to act on a data subject rights request contact us by email at: privacy@fullsail.finance.
- You may exercise these rights by contacting us as set out in the “Contact Us” section.
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- Eligibility
- Legal obligations to disclose
- We may be required to disclose your personal information for the purposes for which it was collected and also subject to our legal obligations:
- as required by law;
- to any person where necessary or desirable in connection with our provision of services; and
- on a confidential basis to our external service providers and advisors.
- To be clear, you consent to our disclosure of your personal information to any of our business partners, suppliers, subcontractors or the like, advertisers and other advertising networks, analytics and search engine providers and other third parties provided the disclosure of your personal information is for the purpose or ancillary to the services that we or these third parties offer you and for the purposes for which the information was originally collected.
- We may share your information with other third party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our services and information we collect about you through the use of cookies and similar technologies.
- You understand that we are authorized to disclose your personal information to third parties if we buy or sell any business or assets, including our business, if we are under a duty to disclose your information, or if the disclosure of your personal information is necessary for us to conduct an investigation into any unlawful activity that we know or suspect has or may be engaged in.
- You consent to the disclosure of all information necessary for our company to comply with any relevant reporting obligations, including AML/KYC and anti-terrorism obligations (if required).
- We will take all reasonable steps to ensure that any overseas recipient of your personal information does not willingly or knowingly breach your relevant privacy laws in relation to your personal information.
- How we store your personal information
- We maintain commercially reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
- When your credit or debit card account, financial account or digital wallet information is being transmitted to our services or through our services, it will be protected by cryptographic protocols. To be clear, we do not ourselves store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We may use third party payment processors that are the controllers of your information. Our contracts with third parties that receive your information require them to keep it secure and confidential.
- However, we cannot guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control.
- We will only keep your information for as long as reasonably necessary to fulfill the purposes for which your personal information was originally collected.
- We will delete your information after a reasonable time. You may be required to re-enter your personal information if it has been deleted.
- You agree and acknowledge that your personal information may be stored at or transferred within the United States or a destination outside of the United States]. This will allow staff operating outside of the United States (whether employed by us or by a third party engaged by us or otherwise authorized under this Privacy Policy to access your personal information) to process your information for the purposes of providing you with our services.
- We will take all reasonable steps and precautions to ensure that any transmission of your personal information via the internet is secure. However, we cannot guarantee the security of any data transmitted to our website and you agree and acknowledge that any such transmissions are at your own risk.
- Once we receive your information, we take reasonable steps to protect your personal information. This may include storing any information on a secure server and employing strict procedures and security features to protect your personal information from any unauthorized recipients and to prevent unauthorized access to the same. We may also store your personal information in physical form.
- All our employees with access to your information will be held to the confidentiality obligations as set out in this Privacy Policy.
- Collection of your information using cookies and other tracking technologies
- Our website and/or other mobile applications use “cookies”. Cookies are small pieces of data sent from a website and stored in your web browser. These pieces of data will allow our website and/or other mobile applications to remember who you are and to obtain information from you which allows us to deliver you a better and more customized service.
- As a result of our website and/or other mobile applications’ use of cookies, we may collect information such as your IP address, online activity and your web browser details. Information that we will not collect or store includes your passwords or other sensitive information.
- We will use both persistent cookies, which could remain on your device until their expiration (which can be, in some cases, up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.
- The types of cookies we may use include analytical and tracking cookies, which allow us to recognize and count the number of visitors and analyse use of the services, as well as to verify transactions, and advertising and re-targeting cookies, which allow us to generate appropriate advertising directed to you on our website.
- If you enabled cookies when accessing our website and/or other mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy.
- Please note that you should also refer to our website’s Terms of Use for further information on this issue.
- Retention of Information
- Security and Storage
- Data Analytics & Advertising
- Analytics are required to provide the Services, improve the Services or for marketing purposes. We collect your consent for these activities where required or where we believe it is correct to do so. This includes analytics completed by Full Sail and third-party services that we use. We also describe how we advertise on third-party sites based on the analytics described here.
- Subject to consent requirements, we may use first-party analytics to provide the Services, including analysing the performance of the Services for product improvement, or for marketing purposes as described above. We may also use third-party web analytics services on the Services (subject to your consent), such as those of Google Analytics. These third-party services use their technology to help us analyse how Users use the Services (such as our websites), including by noting a third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these third parties, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described above. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
- Advertising. Subject to your consent, third-party services, which may include Google Analytics, may use cookies and web beacons to collect information about your activities on the Services (such as our websites) to provide you advertising based upon your interests. This means these third-party services may show our ads on sites across the Internet based upon your previous visits to the Services. Together with these third-party services, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Services.
- The use of tracking technologies by third-parties, technology partners or other third-party assets (such as social media links) on the site is not covered by this Privacy Policy. We do not have access or control over these technologies.
- If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at: www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at: http://aboutads.info/choices.
- Change of Ownership
- Privacy Policy updates
- Complaints
- Contact Us
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- Legal Bases for the Processing of Personal Information
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- In accordance with our legal requirements in this region, we are required to identify and inform you of the legal basis that we use for the processing of your Personal Information. In this section we provide you with information about the legal bases we rely on when processing your Personal Information.
- If you are located in EEA+ our legal basis for processing your Personal Information is described in this section. Please note that more than one legal basis may exist for the processing of your Personal Information:
- Consent.
- This is the case where you have consented to the use of your Personal Information.
- Contract.
- The performance of the contract is used as the legal basis for the processing of your Personal Information for the purpose of providing the Services to you. For example, we need your Personal Information to provide you with our Services, to perform our obligations associated with our contract with you, such as to create and secure your account, to respond to your inquiries or to take steps that you request prior to signing up for the Services.
- Legitimate Interest.
- We have a legitimate business interest in processing your Personal Information to provide the Services to our Customers. We only rely on legitimate interest as a legal basis when the legitimate interests do not override your fundamental rights and freedoms associated with privacy and data protection on balance. We ensure we comply with any requests you make to exercise your associated rights. The processing of your Personal Information where legitimate interests are used as the legal basis for the processing of your Personal Information may include the following purposes: to communicate with you, to optimize our Services, for compliance, fraud and safety purposes and to provide the Services.
- Legal Obligation.
- We may have a legal obligation to process your Personal Information, for example to comply with tax and accounting obligations (which may include anti-money laundering (AML) laws and know-your-customer (KYC) requirements). We may process your Personal Information when necessary to establish, exercise, or defend legal claims.
- Data Protection Officer
- We may have a legal obligation to process your Personal Information, for example to comply with tax and accounting obligations (which may include anti-money laundering (AML) laws and know-your-customer (KYC) requirements). We may process your Personal Information when necessary to establish, exercise, or defend legal claims.
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- International Data Transfers
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- As part of a global business, we need to transfer your Personal Information outside of the EEA +.In this section we describe how we ensure the protection of your Personal information, through the use of safeguards, when we transfer your Personal Information outside the EEA+.
- If you provide us with your Personal Information when using the Services from the EEA, Turkey, Switzerland or the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing.
- When we transfer your Personal Information internationally, we ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, by relying on an EU Commission adequacy decision, or the current standard contractual protections for the transfer of your Personal Information or a derogation if one is available.
- Please contact us using the methods described the “Contact Us” section if you want further information on the specific mechanism used by us when transferring your personal information out of EEA+.
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- Complaints
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- You have the right to contact the appropriate supervisory authority at any time to lodge a complaint regarding the processing of your data. The list of EU supervisory authorities is located here. All other supervisory authorities can be located via a search for their website homepage.
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- Categories of Personal Information We Collect, and How We Use and Share that Information
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- The Personal Information we may collect, use and share over the next 12 months is set out above in the Privacy Policy. Specifically:
- Personal Information we collect is set out at Clause 2 of the Privacy Policy.
- How we use Personal Information we collect is set out at Clause 3 of the Privacy Policy.
- Who we share Personal Information with is set out at Clause 4 of the Privacy Policy.
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- Manage Cookies
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- Sharing of Personal Information
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- We Do Not Sell Your Personal Information
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- Right to Opt-out of Sharing
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- We do not sell your Personal Information, so we do not offer an opt out. We may “share” personal information with third parties for personalized advertising purposes as described above. You may indicate your choice to opt-out of the sharing of your personal data with third parties for personalized advertising on third party sites by contacting us using the methods described in the “Contact Us” Section. You can also opt-out by enabling Global Privacy Control (mentioned above).
- Even if you turn off “sharing,” you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.
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- Non-Discrimination
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- U.S. state privacy laws prohibit businesses from discriminating against you for exercising your rights under the law. Discrimination may include denying services, providing a different level or quality of service, or charging different prices. We do not discriminate.