Last Updated: January 28, 2019
- When you browse or visit our website on fireblocks.com, fireblocks.io, and its subdomains (“Website”);
- When you make use of, or interact with, our Website, our mobile application, mobile software, and any other mobile software application, that we license (each individually, and collectively, the “App”)
- When you create an account and/or log in
- When you download our software / app
- When you provide user information
- When you contact us (e.g. customer support, help, submit a request)
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
What data do we collect when you browse or visit our website?
Additionally, we collect the following information upon account creation and every time a user signs in:
Why is data collected and for what purposes?
- To provide our service and certain features of the product.
- To improve our product and quality of service.
- To create an account.
- To authenticate your access to the services.
- To provide the services.
What is the legal basis for collecting the data (GDPR only)?
- Legitimate interest (e.g. essential cookies)
- Processing is necessary for the performance of a contract and/or legitimate interest
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes
What are the consequences of not providing the data?
- Cannot collect and store the information
- Cannot use or access some parts of the website
- Cannot create an account
- Cannot process the Service order and perform the agreement
- Cannot set up the mobile app
- Cannot assist you and respond your query
How long do we store the collected data?
Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.
2. HOW WE PROTECT AND STORE YOUR INFORMATION
- Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 1, we may share your information as follows:
- To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
- Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
- Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
We ensure transfers within the Fireblocks group will be covered by an agreement entered into by members of the Fireblocks group(an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;
Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Some of these assurances are well-recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
5. YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations), shall apply:
- You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
- You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
- The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
- To the extent you are an individual protected under the GDPR, you have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- To the extent you are an individual protected under the GDPR, you have the right to object to profiling;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
- The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
- To the extent you are an individual protected under the GDPR, you also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at firstname.lastname@example.org. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
6. HOW CAN I DELETE MY ACCOUNT?
Should you ever decide to delete your Account, you may do so by emailing email@example.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services.
7. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS
8. LOG FILES
We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.
9. COOKIES AND OTHER TRACKING TECHNOLOGIES
Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
10. ANALYTIC TOOLS
- Firebase Analytics. We also use a similar tool called “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. In addition, we bring to your attention that:
Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
11. CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
12. OUR CALIFORNIA DO NOT TRACK NOTICE
We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
13. CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at email@example.com.