Privacy Policy

Effective: November 1, 2021

This privacy policy (“policy”) describes how Strike Protocols (“we”, “us”, “our”) collects and uses the personal information that you may provide when accessing and using our app and our website, www.strikeprotocols.com (“App”). It also describes the choices available to you regarding our use of your personal information, your rights in relation to your personal information, and how you can access and update this information.

1. Personal Information We Collect About You. We may collect and use the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, bank account number, credit card number, or any other financial information.
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
  • Geolocation data
  • Video and facial information used to verify your identity.

If you do not provide certain personal information, it may delay or prevent us from providing certain services to you.

2. How Your Personal Information is Collected. We collect most of this personal information directly from you—by telephone, text or email, or via our App.

We may also collect information:

  • Directly from a third party (e.g., our service providers for the online services and our products and services);
  • From a third party with your consent (e.g., your bank, affiliate partners); and
  • From cookies or other online tracking tools on our Services

3. Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our App, 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 App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information. It helps us to improve our App and to deliver a better service.

The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App. We may use third party analytics tools, including Hubspot.

4. Links to Other Apps. Our App may contain links to the websites of third parties whose privacy practices may differ from ours. If you submit personal information to any of these third-party sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or link to from our App.

5. How and Why We Use Your Personal Information. We may use personal information for the following purposes:

  • To provide services to you;
  • To send you requested information;
  • To respond to your requests;
  • To comply with our legal and regulatory obligations;
  • For our legitimate interests or those of a third party, meaning we have a business or commercial reason to use the personal information; or
  • Where you have given consent.

In addition to the foregoing, the table below provides examples of how we may use your personal information and our reasons for such use:

 

How we may use your personal information

Our reasons

To provide services to youFor the performance of our agreement with you or to comply with your requests
To prevent and detect fraud against you or usFor our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Processing necessary to comply with professional, legal and regulatory obligations that apply to our businessTo comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet useFor our legitimate interests, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality controlFor our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive informationFor our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; and to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measuresFor our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Updating and enhancing customer recordsTo comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Marketing our services to:

  • existing and former customers; and
  • third parties who have previously expressed an interest in our services.
For our legitimate interests, i.e. to promote our business to existing and former customers

 

6. Who We Share Your Personal Information With. We will not sell any of your personal information to any outside organization. We only disclose your personal information to third parties as reasonably necessary to carry out the permitted uses described in this policy. For example, we may share personal information with:

  • third parties we use to help us run our business, such as marketing platforms, website hosts, technical and customer support contractors, and other service providers who are required to keep the personal information confidential and are prohibited from using it other than to carry out their services on our behalf;
  • our successors in the event of a sale, merger, acquisition, or similar transaction affecting the relevant portion of our business; and
  • legal and governmental authorities or other third parties, to the extent required to comply with a legal order or applicable law.

We may also disclose personal information that we collect or you provide as described in this privacy policy:

  • If we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our company, our customers, or others;
  • For any other purpose disclosed by us when you provide the information; or
  • With your consent.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number.
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with the App, or advertisement)

7. Where Your Personal Information is Held.We are based in the United States, and personal information collected by us worldwide (including within the European Economic Area) may be transferred to the United States for processing and storage. For example, we may import your personal information into the United States to fulfill our contractual obligations to you. By providing personal information to us, you consent to the transmission of your information outside your own country to be stored in the United States. We take steps to ensure that any such transfer complies with data protection law and that all personal information is secure, including, where appropriate, putting in place standard contractual clauses or implementing other lawful tools and processes for transferring personal information.

8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To comply with laws and regulations and provide to law enforcement agencies;
  • To preserve our business records; and/or
  • To conduct our business operations.

9. European Economic Area (EEA) Residents. If you reside in the European Economic Area (EEA) you may have the following additional rights under the GDPR:

  • The right to access (i.e., the right to be provided with a copy of your personal information);
  • The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
  • The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
  • The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
  • The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
  • The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
  • The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
  • The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and
  • The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).

We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the GDPR by contacting us as follows:

Email: info@strikeprotols.com (please use “GDPR” in the subject line)

The GDPR also gives individuals in the EEA the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

10. California Residents. California consumers have the right to request any of the following information from us regarding personal information collected about you during the preceding 12 months:

  • The categories of personal information collected about you.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom we share personal information, if any.
  • The specific personal information collected about you.
  • For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law.  Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

As a California resident, you have the right to request that we delete any personal information that we have collected about you.  We will honor this request subject to the range of exclusions permitted by law.  For example, we are not required to delete personal information if it is necessary to complete a transaction or reasonably used for an ongoing business relationship or if it is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.

As a California resident, you also have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information.  However, we are permitted to share your personal information with a service provider.

We will not discriminate against you if you choose to exercise any of these rights. California residents may exercise the rights described above by contacting us as follows:

Email: info@strikeprotocols.com  (please use “CCPA” in the subject line)

Phone: (800) 463-1276.

We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

11. Keeping Your Personal Information Secure.  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our services. Any transmission of personal information is at your own risk.

12. Treatment of Minors’ Information. Our App is not intended for children and we do not knowingly solicit or collect personal information from children. If we are notified or discover that a child under the age of 13 has submitted personal information to us, we will take reasonable steps to delete the information.

13. Changes to This Privacy Notice. We may update this policy from time to time. We will always post the then-current version of this policy on our App and will indicate at the top of the policy the date on which the latest version took effect. Please review this policy from time to time to stay updated on our privacy practices.

14. How to Contact Us.

Please contact us if you have any questions about this privacy policy or the information we hold about you.

Email: info@strikeprotocols.com

15. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

Strike Protocols: Simple access to crypto assets
Strike Protocols
111 Congress Avenue, Suite 500
Austin, TX 78701
info@strikeprotocols.com
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