Privacy Notice

 

Last updated November 9, 2022

Thank you for choosing to be part of our community at EMURGO Media Pte Ltd (together with our subsidiaries and affiliates, “EMURGO”, “we”, “us”, or “our”). This Privacy Notice applies to all Personal Data (as defined below) provided to us by you and/or collected through this website, mobile applications, our plug-ins and browser extensions, use of our products and services, sales communications, and marketing or other events (collectively, "Cardano Spot").

We are committed to protecting your Personal Data. When you access or use Cardano Spot, you trust us with your Personal Data. In this Privacy Notice, we describe how we collect, use, store, process and disclose your Personal Data and what rights you have in relation to it. If there are any terms in this Privacy Notice that you do not agree with, please discontinue access and use of Cardano Spot.

Please read this Privacy Notice carefully as it will help you make informed decisions about sharing your Personal Data with us, and to understand our policies and practices regarding your Personal Data and how we will treat it.
 

Key Terms

Personal Data” means any information relating to an identified or identifiable natural person. This includes your name, photo, contact details, address, and other data which can be used alone or in combination with such information to identify you, as well as any other personal information you may input as free text into fields on forms contained on Cardano Spot.

User” and “you” refer to any individual, firm, corporation, organization or other entity who accesses, uses and/or interacts with Cardano Spot.

 

1. Types of Personal Data Collected

Information you provide to us (which includes):

  • Contact data, such as your first name, last name and email address (see also section 14 below);
  • Communications data, such as data that we exchange with you, including when you contact us with questions or feedback, through our services or otherwise;
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them, including your location;
  • Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.

Information from third party sources (see further at section 10 below). Such sources include:

  • Public sources, such as social media platforms and other publicly available sources;
  • Data providers, such as information services and data licensors that provide demographic and other information;
  • Third party vendors, such as service providers providing fraud warnings or enrichment service providers to enhance and personalize your user experience;
  • Marketing partners, such as joint marketing partners and event co-sponsors;
  • Third party platforms or networks, such as Facebook, Instagram, LinkedIn, if you choose to interact with us through such platforms or networks.

Data collected automatically:

  • Usage data, such as information about your interaction with Cardano Spot (e.g. pages or screens you viewed, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.)
  • IP address (the unique address which identifies your computer on the internet) which is automatically recognized by our server when you use/interact with Cardano Spot.

 

2. Use of Data

EMURGO will only use your personal data to the extent permitted by law.

Specifically, EMURGO may use and/or disclose your Personal Data for the following purposes:

  • To notify you about changes to Cardano Spot.
  • To allow you to participate in interactive features of Cardano Spot when you choose to do so.
  • To provide customer support.
  • To gather analytical or valuable information so that we can improve the website, and our products and services.
  • To monitor the usage of Cardano Spot.
  • To detect, prevent and address technical issues.
  • For security purposes and/or to detect fraud or illegal activities.
  • To provide you with news, special offers and general information about other goods, services and events which EMURGO offers that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • To enforce contractual and legal rights and obligations, and/or to prosecute or defend legal actions or other proceedings.
  • To comply with any applicable law, regulation, request from governmental and regulatory authorities, and order of a competent court or tribunal that we may be subject to.
  • Any other purpose(s) for which the Personal Data was requested, and related purposes to fulfil our contractual obligations to you.
  • Any other purpose for which we have obtained your prior informed consent.

Where and as permitted under applicable law, EMURGO may process your contact data for direct marketing purposes (e.g., event invitations, newsletters, marketing or promotional materials and other information that may be of interest to you) and to carry out customer satisfaction surveys, in each case also by email. You may object to the processing of your contact data for these purposes at any time by writing to legal@emurgo.io or by using the opt-out mechanism provided in the respective communication you received.

 

3. Legal Basis under General Data Protection Regulation (GDPR)

For a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), the legal basis for collecting and using Personal Data described in this Privacy Notice depends on the Personal Data being collected and the specific context in which it is collected as described below:

EMURGO may process your Personal Data because:

  • EMURGO needs to perform a contract with you
  • You have given us permission to do so
  • The processing derives from EMURGO's legitimate interests
  • EMURGO has to comply with applicable law

The legal basis for EMURGO processing data about you is that it is necessary for the purposes of:

  • EMURGO exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
  • Compliance with EMURGO’s legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or
  • Legitimate interests pursued by EMURGO (Article 6 (1) (f) General Data Protection Regulation).

Generally the legitimate interest pursued by EMURGO in relation to our use of your personal data is the efficient performance or management of our business relationship with you. In some cases, we may ask if you consent to the relevant use of your Personal Data.

In such cases, the legal basis for EMURGO processing that Personal Data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

 

4. Retention of Data

EMURGO will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice, or as permitted under applicable law. EMURGO will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if EMURGO is required to retain your Personal Data to comply with applicable laws), resolve disputes, and enforce legal agreements and policies.

EMURGO will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Cardano Spot, or EMURGO is legally obligated to retain such data for longer time periods.

5. Transfer Of Data

Please be advised that the Personal Data that we collect from you may be transferred between members of the EMURGO Media and to third parties in connection with the purposes set out above. Therefore, your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Your use of Cardano Spot under the EMURGO Terms of Use followed by your submission of your personal information constitutes your unreserved agreement to this Privacy Policy in general and the transfer of data under this policy in particular.

EMURGO will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

6. Disclosure Of Data

Legal Requirements

EMURGO may disclose your Personal Data in good faith belief that such disclosure is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of EMURGO
  • To prevent or investigate possible wrongdoing in connection with Cardano Spot
  • To protect the personal safety of users of Cardano Spot or the public
  • To protect against legal liability

Disclosure of Personal Information Within The EU

Insofar as we employ the services of service providers to implement or fulfill any tasks on our behalf the contractual relations will be regulated in writing according to the provisions of the European General Data Protection Regulation (EU-GDPR) and the Federal Data Protection Act (new BDSG).”

Disclosure of Personal Information Outside of The EU

Insofar as you have selected and consented to this in the form, your data will be disclosed to our offices within the network of affiliated companies outside of the European economic area for the processing of your enquiry. These offices are legally obligated to abide by the EU-GDPR. Furthermore, between the legally autonomous companies in the network of affiliated companies written agreements exist for the processing of data on commission, based on standardized contract stipulations.

 

7. Security Of Data

We use reasonable technical and organizational methods to safeguard your information, for example, using SSL encryption and firewalls to protect against unauthorized access, disclosure, alteration or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

Whilst we will use all reasonable efforts to safeguard your information, you acknowledge that data transmissions over the internet cannot be guaranteed to be 100% secure and for this reason we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the internet and as such, any information you transfer to EMURGO is done at your own risk.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using Cardano Spot or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of Cardano Spot. We may post a notice on Cardano Spot if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 

8. Rights Under General Data Protection Regulation (GDPR)

If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. EMURGO aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data EMURGO holds about you and if you want it to be removed from our systems, please contact us legal@emurgo.io.

In certain circumstances, you have the following data protection rights:

  • The right to access. You have the right to request information concerning the personal information we hold that relates to you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to your personal information being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
  • The right of restriction. You have the right to request that EMURGO restricts the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information EMURGO has on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where EMURGO relied on your consent to process your personal information.

Please note that EMURGO may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU or EEA.

 

9. California Residents

If you are a California resident, you have certain rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). This section applies to you. We are required to inform you of: (i) what categories of information we collect about you, including during the preceding 12 months, (ii) the purposes for which we use your personal data, including during the preceding 12 months, and (iii) the purposes for which we share your personal data, including during the preceding 12 months.

You have the right to: (i) request a copy of the personal information that we have about you; (ii) request that we delete your personal information; and (iii) opt-out of the sale of your personal information. These rights are subject to limitations as described in the CCPA.

We will not discriminate against any consumer for exercising their CCPA rights.

If you would like to exercise any of these rights, please contact us at legal@emurgo.io.

 

10. Service Providers, Plugins and Tools

 EMURGO may employ third party companies and individuals to facilitate Cardano Spot, to provide the Cardano Spot on our behalf, to perform website-related services or to assist us in analyzing how the Cardano Spot are used ("Service Providers").

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Social Media

EMURGO may use social media plugins to enable a better user experience with the use of Cardano Spot.

 

Youtube

EMURGO uses the YouTube video platform operated by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA. YouTube is a platform that enables playback of audio and video files. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. For information about the scope and purpose of data collection, the further processing and use of the data by YouTube and your rights and the settings you can configure to protect your privacy, please refer to the YouTube Privacy Guidelines.

 

Analytics

EMURGO may use Service Providers to monitor and analyze the use of Cardano Spot.

 

Matomo

EMURGO uses Matomo, an open source web analytics service that is cookieless.

 

Advertising

EMURGO may use an online marketing tool to display adverts on the Cardano Spot.

 

DoubleClick by Google

This website also uses the online marketing tool DoubleClick by Google. DoubleClick uses cookies to serve ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads multiple times. Google uses a cookie ID to determine which ads are running in which browser and can prevent them from being displayed multiple times. In addition, DoubleClick uses cookie IDs to track conversions related to ad requests. For example, if a user sees a DoubleClick ad and later goes to the advertiser’s website with the same browser and buys something there. According to Google, DoubleClick cookies do not contain personally identifiable information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no control over the extent and further use of the data collected by the use of this tool by Google and therefore inform you to the best of our knowledge: By including DoubleClick, Google receives the information that you access the corresponding part of our website or clicked an ad from us. If you are registered with a service provided by Google, Google may associate the visit with your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will find and store your IP address.

You can prevent participation in this tracking process in several ways: a) by adjusting your browser software accordingly, in particular, the suppression of third-party cookies will prevent you from receiving any third-party advertisements; b) by disabling the cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.com/settings/ads, this setting is deleted when you delete your cookies; c) by deactivating the interest-based advertisements of the providers that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies; d) by permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin. We point out that in this case you may not be able to use all the features of this offer in full.

The legal basis for the processing of your data is Article 6 (1) (f) General Data Protection Regulation. To learn more about DoubleClick by Google, visit https://www.google.com/doubleclick and http://support.google.com/adsense/answer/283909 0, and Google’s privacy policy in general: https://www.google.com/intl/en/policies/ privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) web site at http://www.networkadvertising.org. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US Framework

Web Fonts

EMURGO may use online web fonts to display texts and fonts on the Cardano Spot.

 

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Article 6 (1) (f) General Data Protection Regulation.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

 

Newsletter

If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.

We will, therefore, process any data you enter onto the contact form only with your consent per (Article 6 (1) (a) General Data Protection Regulation). You can revoke consent to the storage and use of your data and email address for sending the newsletter at any time, e.g., through the "unsubscribe" link in the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted.

 

Newsletter Tracking

Newsletter tracking (also referred to as Web beacons or tracking pixels) is used if users have given their explicit prior consent. When the newsletter is dispatched, the external server can then record certain data related to the recipient, such as the time and date the newsletter is retrieved, the IP address or details regarding the email program (client) used. The name of the image file is personalized for every email recipient by a unique ID being appended to it. The sender of the email notes which ID belongs to which email address and is thus able to determine which newsletter recipient has just opened the email when the image is called.

You may revoke your consent at any time by unsubscribing to the newsletter. This can be done by sending an email request to unsubscribe to dataprotection@emurgo.io. You may also remove yourself from the mailing list using the unsubscribe link in the newsletter.

 

11. Links To Other Products

Cardano Spot may contain links to other products that are not operated by EMURGO. If you click on a third-party link, you will be directed to that third party's site. You are advised to review the privacy notice of each non-EMURGO site you decide to visit.

EMURGO has no control over and assumes no responsibility for the content, privacy notices or practices of any third-party product or service.

 

12. Changes To This Privacy Notice

EMURGO may update this Privacy Notice from time to time. Such changes will be posted on this page. The effective date of such changes will be notified via email and/or a prominent notice on the Cardano Spot, with an update the "effective date" at the top of this Privacy Notice.

You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.

 

13. Data Privacy Contact

You can reach our data protection officer at dataprotection@emurgo.io

 

14. Contact by E-mail or Contact Form

When you contact us by e-mail or through a contact form, we store the data you provide (your email address, possibly your name and telephone number) so we can answer your questions. Insofar as we use our contact form to request entries that are not required for contacting you, we have marked these as optional. This information serves to substantiate your inquiry and improve the handling of your request. Your message may be linked to various actions taken by you on the Cardano Spot website. Information collected will be solely used to provide you with support relating to your inquiry and better understand your feedback. A statement of this information is expressly provided on a voluntary basis and with your consent. As far as this concerns information about communication channels (such as e-mail address or telephone number), you also agree that we may, where appropriate, contact you via this communication channel to answer your request. You may of course revoke this consent for the future at any time.

We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.