Overview

Your privacy is important to us. Block79 Inc. (“Block79”, “we”, or “us”) wants you to be familiar with how we collect, use and disclose your Personal Information.

This Privacy Policy (“Policy”) explains how we collect, use, and disclose your Personal Information when you visit or use services made available through our websites (“Websites”) and associated platforms operated by us from which you are accessing this Policy (collectively, the “Services”) including:

• The Block79 network, through which you are able to access and interact with a foundational layer for securities tokens.
• The Block79 Wallet available as a browser extension through which you are able to manage your (i) digital assets created on Block79; and (ii) Block79’s native protocol token.

This Policy also describes other important topics relating to your privacy.

Modifications

We may change this Policy from time to time. If we make material changes, we will take reasonable steps to notify you, such as by revising the effective date at the top of the Policy or placing a notice on our Websites and associated platforms through which you use our Services, or at our discretion, contacting you using any contact information you have provided. We encourage you to review the Policy whenever you access the Services to stay informed about our information practices.

Summary

The following is a short summary of the key elements of this Policy. You can read the full version of the Policy following this summary.

‍

We may collect the following Personal Information and other information from you:

• Your name;
• Your e-mail address;
• Your phone number;
• Information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us; and
• Online identifiers such as general geographic location, IP address, and details regarding your use of the Services.

We may use your Personal Information for the following purposes:

• To provide you with the functionality of the Services;
• To contact you regarding your use of the Services;
• To understand how you and our users use the Services in order to improve the Services, and our marketing efforts; and
• For other purposes required by applicable law, including confirming your identity to comply with our regulatory obligations.

We may share your Personal Information with the following parties / for the following purposes:

• To service providers selected by you in your use of the Services;
• To other third-party service providers to facilitate services they provide to us, including analytics providers that help us understand how our Services are used; and
• As otherwise required by applicable law.

How to contact us:

• If you have questions about this Policy or would like to contact us regarding the collection, use and disclosure of your personal information, please contact us at support@block79.com

What Personal Information Do We Collect About You?

Personal Information refers to any information about an identifiable individual.

We collect the following Personal Information and other information when you request to open an account on Block79 and our Services provided on Block79, including Block79 Token and Block79 Wallet:

• Your name;
• Your e-mail address;
• Your phone number (mobile).

We also collect information that you provide directly to us when you access and use the Services, including:

• Information that you provide when you request that a token be configured using the Services, such as information describing the tokens and the issuer as well as e-mail addresses for intended token recipients;
• Information regarding the services you use, such as information you provide for identification purposes, such as your name, nationality, and birth date; and
• Information that you provide when you request customer support from us.

Please note that where you provide us with the information of another person such as a token recipient, you must have their permission to give it to us for that purpose.

Information that we Collect 

When you access or use the Services, we collect certain information using cookies, web beacons, and similar tracking technologies. Cookies are small data files stored directly on the device you are using that allow us to collect information to help the Services function properly, and to report on activities and trends so that we can improve the services. This information includes:

• Online identifiers such as IP address, geolocation, device information, and browser type;
• Details regarding how you interact with the Services, such as time spent on the Services and which links you click on; and
• Metrics such as number of visitors to our Websites, pages visited, frequency of clicks to assess behaviors, usage data, failed attempts, spam attempts, and similar information.

Your browser gives you the ability to reject cookies. However, setting your browser or device to reject cookies generally hinders performance and may adversely affect your experience while using the Services.

How do we use your Personal Information?

Information we collect is used by Block79 and its service providers to:

• Provide you with the functionality of the Services and fulfil your requests, for example;
• Create your account and associated decentralized identity to enable you to access the Services;
• Create your Block79 Wallet to enable you to access the Services;
• Send you technical notices, updates, security alerts and support and administrative messages including confirmations and receipts;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, and events we think will be of interest to you;
• To understand users and potential users and their interests in Block79 products and services, manage our relationship with users, enhance user experience on our platform and applications, improve our platforms and applications;
• Monitor and analyze trends, usage and activities in connection with our Services so that we can improve our Services;
• Conduct audits to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• Carry out any other purpose for which the information was collected and for which you have provided your consent; and
• For other purposes that are permitted or required by applicable law such as verifying your identity in accordance with our client identification requirements.

We may aggregate and anonymize Personal Information so that it may not be used to identify you or any other individual. We do so to generate data for our use, which we may use and disclose for any purpose, if permitted by applicable law.

Who do we share your information with?

We share information about you as follows or as otherwise described in this Policy:

• To service providers selected by you in order to request services on your behalf. You, and not us, are responsible for your selection of and relationship with such service providers. For information about how they process your Personal Information please refer to their Privacy Policy(ies).
• To analytics vendors, including Google Analytics, in order to help understand how users interact with the Services, including to understand users and potential users and their interests in Block79 products and services, to manage our relationship with users, enhance user experience on our platform and applications, improve our platforms and applications. These services may also collect information regarding the use of other websites, apps, and resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at: https://tools.google.com/dlpage/gaoptout.
• To other third-party service providers that assist us with carrying out the purposes we describe in this Privacy Policy. We provide them information to facilitate services they provide to us. This includes providers of services such as website hosting, information technology, auditing, and other services contemplated by this Policy. For the purposes of the European Data Protection Laws, these service providers act as our processors.
• In response to a request for information if we believe disclosure is required or permitted in accordance with any applicable law, regulation or legal process;
• To cooperate with law enforcement, protect our rights or those of third parties (for example, to detect and prevent fraud), or as otherwise required by any applicable law;
• In connection with, or during negotiations of, any merger, consolidation, restructuring, sale of company assets, or disposition of all or a portion of our business to another company, including, without limitation, during the course of any due diligence process; and
• With other third parties when we have your consent.

This Policy does not apply to third party sites

Our Services may contain links to websites owned by third parties. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit.  Any links from our Services to other websites, or references to products, services or publications other than those of Block79, do not imply the endorsement or approval of such websites, products, services or publications by Block79.

Access and Correction

You may request access to your Personal Information and to request a correction if you believe it is inaccurate.

Please contact us by e-mail at support@block79.com if you would like to exercise either of these options. Please note that in some circumstances we may not be able to allow you to access certain Personal Information, for example if it contains Personal Information of other persons, or for legal reasons. We may require you to verify your identity before allowing you to access your Personal Information.

Contact Us

If you have any questions about this Policy, please contact our Policy Department at support@block79.com.

You may also contact our Privacy Officer in our affiliate office at…

Overview

Your privacy is important to us. Block79 Inc. (“Block79”, “we”, or “us”) wants you to be familiar with how we collect, use and disclose your Personal Information.

This Privacy Policy (“Policy”) explains how we collect, use, and disclose your Personal Information when you visit or use services made available through our websites (“Websites”) and associated platforms operated by us from which you are accessing this Policy (collectively, the “Services”) including:

• The Block79 network, through which you are able to access and interact with a foundational layer for securities tokens.
• The Block79 Wallet available as a browser extension through which you are able to manage your (i) digital assets created on Block79; and (ii) Block79’s native protocol token.

This Policy also describes other important topics relating to your privacy.

Modifications

We may change this Policy from time to time. If we make material changes, we will take reasonable steps to notify you, such as by revising the effective date at the top of the Policy or placing a notice on our Websites and associated platforms through which you use our Services, or at our discretion, contacting you using any contact information you have provided. We encourage you to review the Policy whenever you access the Services to stay informed about our information practices.

Summary

The following is a short summary of the key elements of this Policy. You can read the full version of the Policy following this summary.

‍

We may collect the following Personal Information and other information from you:

• Your name;
• Your e-mail address;
• Your phone number;
• Information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us; and
• Online identifiers such as general geographic location, IP address, and details regarding your use of the Services.

We may use your Personal Information for the following purposes:

• To provide you with the functionality of the Services;
• To contact you regarding your use of the Services;
• To understand how you and our users use the Services in order to improve the Services, and our marketing efforts; and
• For other purposes required by applicable law, including confirming your identity to comply with our regulatory obligations.

We may share your Personal Information with the following parties / for the following purposes:

• To service providers selected by you in your use of the Services;
• To other third-party service providers to facilitate services they provide to us, including analytics providers that help us understand how our Services are used; and
• As otherwise required by applicable law.

How to contact us:

• If you have questions about this Policy or would like to contact us regarding the collection, use and disclosure of your personal information, please contact us at support@block79.com

What Personal Information Do We Collect About You?

Personal Information refers to any information about an identifiable individual.

We collect the following Personal Information and other information when you request to open an account on Block79 and our Services provided on Block79, including Block79 Token and Block79 Wallet:

• Your name;
• Your e-mail address;
• Your phone number (mobile).

We also collect information that you provide directly to us when you access and use the Services, including:

• Information that you provide when you request that a token be configured using the Services, such as information describing the tokens and the issuer as well as e-mail addresses for intended token recipients;
• Information regarding the services you use, such as information you provide for identification purposes, such as your name, nationality, and birth date; and
• Information that you provide when you request customer support from us.

Please note that where you provide us with the information of another person such as a token recipient, you must have their permission to give it to us for that purpose.

Information that we Collect 

When you access or use the Services, we collect certain information using cookies, web beacons, and similar tracking technologies. Cookies are small data files stored directly on the device you are using that allow us to collect information to help the Services function properly, and to report on activities and trends so that we can improve the services. This information includes:

• Online identifiers such as IP address, geolocation, device information, and browser type;
• Details regarding how you interact with the Services, such as time spent on the Services and which links you click on; and
• Metrics such as number of visitors to our Websites, pages visited, frequency of clicks to assess behaviors, usage data, failed attempts, spam attempts, and similar information.

Your browser gives you the ability to reject cookies. However, setting your browser or device to reject cookies generally hinders performance and may adversely affect your experience while using the Services.

How do we Use your Personal Information?

Information we collect is used by Block79 and its service providers to:

• Provide you with the functionality of the Services and fulfil your requests, for example;
• Create your account and associated decentralized identity to enable you to access the Services;
• Create your Block79 Wallet to enable you to access the Services;
• Send you technical notices, updates, security alerts and support and administrative messages including confirmations and receipts;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, and events we think will be of interest to you;
• To understand users and potential users and their interests in Block79 products and services, manage our relationship with users, enhance user experience on our platform and applications, improve our platforms and applications;
• Monitor and analyze trends, usage and activities in connection with our Services so that we can improve our Services;
• Conduct audits to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• Carry out any other purpose for which the information was collected and for which you have provided your consent; and
• For other purposes that are permitted or required by applicable law such as verifying your identity in accordance with our client identification requirements.

We may aggregate and anonymize Personal Information so that it may not be used to identify you or any other individual. We do so to generate data for our use, which we may use and disclose for any purpose, if permitted by applicable law.

Who do we share your information with?

We share information about you as follows or as otherwise described in this Policy:

• To service providers selected by you in order to request services on your behalf. You, and not us, are responsible for your selection of and relationship with such service providers. For information about how they process your Personal Information please refer to their Privacy Policy(ies).
• To analytics vendors, including Google Analytics, in order to help understand how users interact with the Services, including to understand users and potential users and their interests in Block79 products and services, to manage our relationship with users, enhance user experience on our platform and applications, improve our platforms and applications. These services may also collect information regarding the use of other websites, apps, and resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at: https://tools.google.com/dlpage/gaoptout.
• To other third-party service providers that assist us with carrying out the purposes we describe in this Privacy Policy. We provide them information to facilitate services they provide to us. This includes providers of services such as website hosting, information technology, auditing, and other services contemplated by this Policy. For the purposes of the European Data Protection Laws, these service providers act as our processors.
• In response to a request for information if we believe disclosure is required or permitted in accordance with any applicable law, regulation or legal process;
• To cooperate with law enforcement, protect our rights or those of third parties (for example, to detect and prevent fraud), or as otherwise required by any applicable law;
• In connection with, or during negotiations of, any merger, consolidation, restructuring, sale of company assets, or disposition of all or a portion of our business to another company, including, without limitation, during the course of any due diligence process; and
• With other third parties when we have your consent.

This Policy does not apply to third party sites

Our Services may contain links to websites owned by third parties. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit.  Any links from our Services to other websites, or references to products, services or publications other than those of Block79, do not imply the endorsement or approval of such websites, products, services or publications by Block79.

Access and Correction

You may request access to your Personal Information and to request a correction if you believe it is inaccurate.

Please contact us by e-mail at support@block79.com if you would like to exercise either of these options. Please note that in some circumstances we may not be able to allow you to access certain Personal Information, for example if it contains Personal Information of other persons, or for legal reasons. We may require you to verify your identity before allowing you to access your Personal Information.

Contact Us

If you have any questions about this Policy, please contact our Policy Department at support@block79.com.

You may also contact our Privacy Officer in our affiliate office at…