Effective date: April 18, 2022
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. The Services is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
What Information does FLUIDEFI Collect?
Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, this includes information you provide when you import your Wallet such as information regarding your transactional history on the Ethereum or Binance networks, the information you provide each time you wish to make a transfer of virtual currency through the Services, or usage information, such as information about how you use the Services and interact with us. It also includes (i) contact information you elect to provide to us such as your email address, (ii) feedback and correspondence, such as information you provide in your responses to surveys, to report a problem with our Services, or otherwise correspond with us, and (iii) marketing information, such as your preferences for receiving marketing communications and details about how you engage with them. Other than the information required to associate your Wallet with the Platform or Website, you are not required to provide any other Personal Information to use the basic features of our Services, but you may be required to provide additional Personal Information to access additional features or offerings.
You should understand that, because of the nature of the Ethereum network, your entire transactional history conducted from your Wallet is provided to us or otherwise publicly accessible by default and is necessary to support your usage of the Services.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services. For example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
We do not automatically collect Personal Information or other nonpublic information in connection with transactions on the Ethereum network you conduct using our Services through the Platform or Website, and we do not use any automatic tracking technologies in these parts of our Services unless you explicitly agree to the use of these tracking technologies.
Do Not Track Policy: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.
Information we will never collect: We will never ask you to share your private keys to your Wallet or other security information that could be used to access your Wallet without your explicit consent and action. FLUIDEFI strongly recommends you perform thorough and careful due dillegence on anyone or any website that asks you to enter your private keys or similar security information.
How does FLUIDEFI Use the Personal Information it Receives?
As a general policy, we aim to protect your privacy and Personal Information by collecting, using or sharing as little Personal Information as possible in order to provide our Services unless you explicitly agree in writing to additional collection, use or sharing.
To the extent we do use Personal Information, we use such information to provide and improve the Services, optimize our technology, refine the experience of our users, and innovate ways to forward our mission.
Namely, we use the information we collect to:
- Administer the Services, enable you to use its features, and improve your overall user experience;
- Send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;
- Respond to comments and questions and provide customer service;
- Analyze how users use the Services to help us optimize the Services and know if there are problems with the Services;
- Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
- With your consent, to link or combine user information with other Personal Information;
- To provide and deliver products and services requested by customers; and
Will FLUIDEFI Share Any of the Personal Information it Receives?
- Consent: We may share Personal Information with your explicit consent.
- Affiliated Businesses: In certain situations, businesses or third-party websites we are affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all of these businesses’ or websites’ policies.
- Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you or to us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
- Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
When we share Personal Information, we will not share such Personal Information in a manner that can be used to identify you individually or in a manner that provides more Personal Information than is publicly available (if applicable) unless otherwise explicitly agreed by you or instructed by you, and unless we are legally required to do so.
Is Personal Information about me secure?
We endeavour to protect the privacy of the Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. The safety and security of your Personal Information also depends on you. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Your Wallet is protected by your password, private key, and/or seed phrase, and we urge you to take steps to keep this and other Personal Information safe by not disclosing your security credentials or leaving your Wallet open in an unsecured manner. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. We also seek to protect Personal Information by refraining from collecting Personal Information where possible. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Services, you acknowledge that you understand and agree to assume these risks.
WE DO NOT AND WILL NEVER STORE YOUR WALLET PASSWORD, PRIVATE KEY, OR SEED PHRASE TO YOUR WALLET. IF YOU LOSE ACCESS TO BOTH YOUR PASSWORD AND SEED PHRASE, WE WILL BE UNABLE TO HELP YOU ACCESS YOUR WALLET, AND ANY ASSETS HELD IN THE WALLET MAY BE PERMANENTLY IRRETRIEVABLE.
If you are a resident of the European Economic Area (“EEA”) or Switzerland, you may have additional rights under the General Data Protection Regulation (the “GDPR”) and other applicable law with respect to your Personal Data, as outlined below.
For the purpose of this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. FLUIDEFI will be the controller of your Personal Data processed in connection with the Services.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
What Personal Data Do We Collect from You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
- Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation, Personal Information as described above under “Information You Provide to Us” and “Information Collected from Other Sources”, and any other information you may elect to submit in your communications with us while using our Services. You are not required to submit Personal Data solely in connection with your use of your Wallet through our Services, but certain of our other Services may require submission of Personal Data to fully exploit those Services.
- Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, including without limitation, the information described above under “Information Collected Automatically.”
How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. See “How does FLUIDEFI Use the Personal Information it Receives?” for more information on how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Legitimate Interest: We may also process your Personal Data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We consider and balance any potential impacts on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law). Examples of these legitimate interests include operation and improvement of our business, products and Services, provision of customer support, protection from fraud or security threats, compliance with legal obligations or completion of corporate transactions.
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
How and With Whom Do We Share Your Data?
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as necessary to provide you Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity, and, where possible, we refrain from collecting Personal Data. For example, FLUIDEFI does not collect private key data associated with your Wallet, and we secure the Personal Data you provide in a controlled, secure environment that is protected from unauthorized access. FLUIDEFI regularly audits its system for any possible security vulnerabilities to safeguard Personal Data. FLUIDEFI protects the security of your information during transmission by using Transport Layer Security (TSL/SSL), which encrypts all information that you input. However, your private key is the key to your Wallet. If you do share your private key or your Personal Data with others that enables them to access your private key, you remain responsible for all actions taken in the name of your Wallet. If you lose control of your private key, you may lose control over your Wallet and/or your Personal Data and may be subject to legally binding actions taken on your behalf.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by visiting the Platform or Website.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by editing them on the Platform or Website.
- Erasure: You can request that we erase some or all your Personal Data from our systems, provided that this will not erase any Personal Data you have submitted to the Ethereum network.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about FLUIDEFI’s practices with respect to your Personal Data with the supervisory authority of your country or European Union Member State.
Transfers of Personal Data
What If You Have Questions Regarding Your Personal Data?
If you have any questions about this section or our data practices generally, please contact us using the following information:
- Designated Representative Name: Data Protection Officer
- Physical address: 4149 de Mentana Street, Montreal, Quebec, H2L 3S3
- Email address for contact: email@example.com
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to firstname.lastname@example.org, and we will try to resolve your concerns.
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at email@example.com.
Your California Privacy Rights
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information” (as defined in this section), as well as rights to know/access, delete, and limit sharing of Personal Information.
The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. Your rights are described below:
Right to Notice at Collection Regarding the
Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.
- Identifiers. We collect your name, phone number, contact address and e-mail address when you engage with our website. We use this information to manage and provide the Services that you request, respond to your requests, and to communicate with you about the Services. We collect your social media handle when you interact with our Services through social media. We use this information to improve the user experience and our Service.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). In addition to the identifiers in the above section, we collect your credit card number to provide you with requested Services.
- Internet or other similar network activity. We automatically collect information about your browsing history and your interaction with the content of our Services to measure activity, determine the effectiveness of our Services, and improve them.
- Sensory Data. We collect your audio or voice recordings to provide you with Services.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
Right to Know/Access Information
You have the right to request access to Personal Information collected about you over the past 12 months and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
How to Submit a Request
You may submit a request to exercise your rights to know/access or delete your Personal Information by sending us an email at firstname.lastname@example.org.
Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.
In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your Personal Information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to Personal Information previously collected by us.
If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.
You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.
Right to Opt-Out of Sale of Personal Information to Third Parties
You have the right to opt-out of any sale of your Personal Information by us to third parties. We do not sell information to third parties.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.April 18