Privacy Policy
Last updated: March 27, 2023
1. Introduction
As part of our daily business operations, we collect personal information from our users and prospective users in order to provide them with our services (hereinafter collectively, “Services”), and ensure that we can meet their needs when providing these services, as well as when providing them with any respective information.
Your privacy is of utmost importance to us, and we are committed to protecting your personal data. This Privacy Policy (”Policy”) applies to the processing of personal data by GetPass (“Company”, “we”) in connection with: use of any of Services; visit or use of the internet website, the address of which is https://getpass.io (hereinafter „Website“) to the extent related to Services.
The Policy describes: the types of information that we may collect from you when you access or use our Website or Services; and our practices for collecting, using, protecting and disclosing that information. The Policy also informs you of your rights with respect to the processing of your personal information.
The Policy is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment.
Please note that the Website and Services are not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.
Please note that if you are an employee of the Company, a contractor to the Company or a third-party provider, your personal information will be used in connection with your employment contract or your contractual relationship, whichever applies.
2. Responsibilities and Data Controller
GetPass is responsible for data protection on the Website, unless expressly stated otherwise. You can contact us in data protection matters at support@getpass.io.
For conducting cryptocurrency transactions, we use third-party electronic wallet extensions such as (but not limited to) MetaMask (https://metamask.io), Coinbase (https://coinbase.com) and the list of wallets offered by WalletConnect (https://walletconnect.com/). None of the wallets and accounts are operated by us or are under our control from a legal or privacy perspective.
All transactions on the platform are conducted in ERC-20 tokens based on Ethereum blockchain. GetPass is neither a part of the Ethereum organization nor directly affiliated with its business activities. We can therefore neither guarantee availability of the Ethereum blockchain including its technical and software elements 100% of the time nor its proper functioning with regard to every individual transaction. This limitation specifically includes situations where a third party receives unauthorized access to any and all transactions, assets or files.
With regard to the use of data in, data processing always takes place outside of sphere of influence of GetPass, therefore, the sender of the information or transactions made on and via the smart contract qualifies as a controller.
3. How do we protect personal information?
We have implemented appropriate measures in the form of various technical, physical and other means, including, but not limited to measures regarding the security of our electronic systems and databases. These means aim at improving the integrity and security of the personal information that we collect and maintain. However, please be advised that even the best security measures cannot guarantee the full elimination of all risks. If we learn of any violation, breach or danger to our security systems breach, then we will attempt to notify you electronically so that timely and appropriate protective steps can be taken. Apart from informing you via e-mail, we may post a notice through the Website if a security breach occurs.
4. Information we may collect about you
GetPass may collect and use information of and regarding its users. We collect only data which is essential to our operations and enables us to provide you with better user experience. The information we collect on or through Website and Services may include:
Сontact information, such as e-mail or other ways of communication. We collect this information in order to provide you with access to certain features of Services and to inform you about relevant information concerning your use of Services.
Browsing information. How long you used Services, which features you used. We collect this information in order to analyse the behaviour of our users and improve Services.
Communications between you and GetPass support staff regarding Services. We collect this information in order to monitor the quality of our support staff and your communications with us.
Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions.
We also may use Google Analytics (https://www.google.com/analytics/terms/us.html.), Mixpanel (https://mixpanel.com/legal/privacy-policy/) and Intercom (https://www.intercom.com/legal/privacy) to help us offer you an optimized user experience.
5. Disclosure of your personal information
The Company will not disclose any of its users’ confidential information to a third party, except: to the extent that it is required to do so pursuant to any applicable laws, rules or regulations; if there is a duty to disclose; if our legitimate business interests require disclosure; in line with our Terms of Service; at your request or with your consent or to those described in this Policy. The Company will endeavour to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notify the third party regarding the confidential nature of any such information.
As part of using your personal information for the purposes set out above, the Company may disclose your personal information to the following:
Any members of the Company, which means that any of our affiliates and subsidiaries may receive such information;
Any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services.
6. Your rights regarding your personal information
Access - You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information.
Update - You have a right to request an update to any of your personal information which is out of date or incorrect.
Delete - You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.
Restrict - You have a right to ask us to restrict the way that we process your personal in-formation in certain specific circumstances.
Transfer - You have a right to ask us to provide your personal information to a third-party provider of services.
Object - You have a right to request to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
7. Cookies
When you use our Website, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (hereinafter, “Cookies”) on your computer or other devices used when engaging with us. We use Cookies to help us recognize you as a customer and collect information about your use of our Website.
8. Changes to the Policy
GetPass reserves the right, at its sole discretion, to modify or replace this Policy at any time. If a revision is material, GetPass will provide at least 30 days notice prior to any new terms taking effect. The continued use of the Website and Services after the end of notification period will constitute an acceptance of the revised Policy. What constitutes a material change is determined at GetPass’s sole discretion.
9. Contact
In order to address a question, to resolve a complaint regarding the Website or Services, or to receive further information regarding the services, please contact GetPass via e-mail at support@getpass.io
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