Effective Date: Oct 8, 2021
How and why we collect your Personal Information
How your Personal Information is used and protected
When and with whom we share your Personal Information
What choices you can make about how we collect, use, and share your Personal Information
How we may store, retain, and transfer your Personal Information
Your rights (where applicable) to learn about the Personal Information we collect, and what you can request that we do with it
If you are a citizen or resident of the European Economic Area (“EEA“), United Kingdom, or Switzerland, the definition of personal information is defined under the General Data Protection Regulation (“GDPR”) and you have certain rights; therefore, please see the section below entitled “GDPR”.
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
We collect several categories of Personal Information from and about you as summarized in the following table:
Specific Items of Personal Information
first and last name, user name, email address
national origin, country of residence
products/services purchased on our website
cryptocurrency wallet address
Internet or other electronic network activity
products/services purchased on our website
browsing, session, interaction, and search history related to our Website, Internet Protocol (or IP) address, protocol, and sequence information, cookies
Information You Provide Us. The Personal Information we collect through our Website, or from our representatives, business partners, or service providers may be obtained as part of the following:
Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, Products, or Services, or otherwise communicating with us.
Records and copies of your correspondence (including email addresses), if you contact us
Registering for an event
Your responses to surveys that we or our service providers might ask you to complete for research purposes
Your search queries on the Website
When communicating with customer service/support
Through participation in loyalty/rewards programs
Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
On mobile applications (parent, subsidiary and affiliate brands)
Joint marketing partners
Social media companies
Other service providers
Responding to employment opportunities
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
Behavioral Tracking. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.
The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Google, Instagram, etc.), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
A cookie is a small file placed on the hard drive of your computer or mobile device. Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. More information on how to opt-out of third-party advertiser tracking mechanisms here.
You also may submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. By posting any Content or submitting Content for posting you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, redact, modify, aggregate, summarize, adapt, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”).
The Right to Use you grant us above also extends to any Content that you have posted to our social media account pages, or on other websites, e.g., Google. The term “Use” includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the content.
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
To present our Website and its contents to you.
To provide you with information and respond to your questions on Products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
To provide you with the Products, Services, or information that you have requested.
To process transaction payments, including, but not limited to, product and/or service fees, subscription fees, professional fees, membership dues, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number).
To process discounts, offers, loyalty rewards.
To provide you with notices about your account, including expiration and renewal notices.
To notify you about information regarding or changes to our Website, our policies, terms, or any Products or Services we offer or provide, or regarding your account.
To process your account application and any changes to your account information.
To process Personal Information or other information that you submit through to us.
To allow you to participate in interactive features on our Website.
To contact you about our own and third-parties’ products and services that may be of interest to you.
To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.
To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.
For internal purposes, such as Website and system administration or internal audits and reviews.
For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
To operate, maintain, and provide to you the features and functionality of the Services.
To provide statistics about the usage levels of the Website and other related information to our service providers.
To notify you of data privacy incidents or provide you with legally required information.
To fulfill any other purpose for which you provide Personal Information.
In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.
Text Messages. We use the information we collect about you to deliver the Services we offer, and to operate and improve our Website. Our services may include a Short Message Service (“SMS”) which may deliver up to two messages per day to your wireless device. We may use your information to contact you about your purchases, Website updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received or by responding to the SMS you received from us with “STOP. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us, or by any reasonable means. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. For help, please reply to a text with HELP. Message and data rates may apply, depending on your cell phone plan. Carriers are not liable for delayed or undelivered messages.
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:
Data storage or hosting providers for the secure storage and transmission of your data
Software and data service providers for the management and tracking of your data
Technology providers who assist in the development and management of our Website
Identity management providers for authentication purposes
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
Payment solution providers for the secure processing of payments you provide to us
Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, marketing assistance, creating, hosting, and/or providing customer or support services on our behalf, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
SALE/DISCLOSURE OF PERSONAL INFORMATION
No Sale of Personal Information. We do not disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration. In other words, we do not sell your Personal Information, period.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information. You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (“Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the UK, European Economic Area (“EEA”), or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the UK, EEA, or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses, where applicable. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the UK, EEA, or Switzerland, or if you use our services and products while visiting countries outside this area.
If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.
If you are a citizen or resident of the UK, EEA, Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff operating outside the these countries who work for us or for one of our service providers.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe.
Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
You hereby release and forever discharge us and our affiliates, subsidiaries, officers, directors, employees, and agents, and their respective successors and assigns, and you will indemnify, defend and hold us harmless, from and against any liability, claim, or cost (including attorneys’ fees), arising directly or indirectly from any failure by you to maintain the security of your email or other accounts that directly or indirectly results in an unauthorized third party having access to such email or accounts or causes us to transfer funds based on instructions purporting to have originated from you (i.e., “wire transfer fraud” or “business email compromise” events).
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, or hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.
The time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
We may retain De-Identified Personal Information for as long as we deem appropriate.
Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
The following in this section applies only to California residents.
California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here):
CalOPPA applies only to companies which collect Personal Information of California residents.
How We Respond to Do Not Track Signals.
CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, see here. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
Third-Party Behavioral Tracking. We do not allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
By providing us with your email address (including by “following,” “liking,” linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Website, your Personal Information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
Our Legal Basis for Processing Personal Data (UK, EEA, and Swiss Visitors Only)
If you are a visitor using our Website from the UK, EEA or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we need the Personal Data to perform Services for you for which you have contracted with us, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
Your Data Rights Under GDPR
If you are subject to GDPR, your rights include the following:
The right to access - Upon request, we will confirm any processing of your Personal Information and, and provide you with a copy of that Personal Information in an acceptable machine-readable format.
The right to rectification - You have the right to have us correct any inaccurate Personal Information or to have us complete any incomplete Personal Information.
The right to erasure - You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion).
The right to restrict processing - You have the right to ask us to suppress the processing of your Personal Information but we may still store your Personal Information. See below for more information.
The right to object to processing - You have the right to object to your Personal Information used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and, (c) processing for purposes of scientific/historical research and statistics. See below for more information.
The right to data portability - You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly used and machine-readable format.
The right to complain to a supervisory authority - You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
The right to withdraw consent - If we are processing your Personal Information based on your consent to do so, you may withdraw that consent at any time.
What is the legal basis?
We collect and process your personal information in compliance with the GDPR and the applicable EU laws.
Collection and processing is based on your consent: Art. 6(1)a GDPR, Art. 4(11) GDPR
We will always ask for your consent to collect and process your personal information for the aforementioned specific purposes, unless the collection and processing of your personal information is permitted by statutory laws. Where you have provided us with your consent to the collection and processing of your personal information for the aforementioned specific purposes, you have the right to withdraw your consent at any time.
Collection and processing is necessary for taking steps prior to enter into a contract: Art. 6 (1)b GDPR
The collection and processing of your personal information may be necessary for the performance of a contract to which you may be a party. Prior to entering into such contract, the collection and processing of your personal information may also be necessary in order to take steps at your request. This applies for installation and the use of our extension as well as any payment processing in connection with donations.
Collection and processing is necessary for compliance with a legal obligation to which the Controller is subject: Art. 6 (1)c GDPR
Collection and processing of your personal information may be necessary for compliance with a legal obligation to which we are subject under EU laws or the laws of a EU Member State.
Collection and processing is necessary for the purposes of our legitimate interests: Art. 6 (1)f GDPR
The collection and processing of your personal information may be necessary for the purposes of our legitimate interests. Such legitimate interest purposes may include:
ensuring network and information security
when we are complying with legal obligations
processing employee or visitor, member, attendee, or registrant data
performing the function or service you requested of us
providing our services and their functionality to you where such processing is necessary for the purposes of the legitimate interests pursued by us or by our service providers related to the services
the relevant and appropriate relationship we have with you
analytics, e.g., assess the number of visitors, page views, use of the Site, etc., in order to understand how our Site and services are being used, to optimize the Site and/or future communications, and to develop new services and Site features
updating your information and preferences
offering and improving our services