Effective: October 2022
Last Updated: October 2022
Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message, or other electronic message or offline. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.
Depending on applicable law of your jurisdiction, you may be able to assert certain rights related to your personal information. Please note that rights are not absolute and may be subject to conditions. Please see the additional notices below for California and Vermont residents. If you are visiting the Site from the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), see our Notice to Certain European Data Subjects below for our legal bases for processing and transfer of your data. To the extent we collect personal information from such users, Harbor Labs is the “controller” of such data for purposes of GDPR.
2. TABLE OF CONTENTS
3. WHAT WE COLLECT
We may get information about you in a range of ways, though we currently do not contemplate the collection of users’ personal information. We may collect certain non-personally identifiable information from you and other information collected automatically. Further, we may collect non-personally identifiable information about you that can be linked with other information to reasonably identify you. In any regard, we aim to provide the Services in a manner that collects no personal information from users or as little personal information as possible if we collect personal information in the future or when you voluntarily provide it to us.
Information You Give Us. Information we collect from you may include:
When you create a wallet through our Services, encrypted wallet public key and private key pairs are automatically generated by the software and stored in encrypted form. We do not store the passwords required to decrypt public or private keys. In no event will we ask you to share your private keys or wallet seed. Never trust anyone or any website that asks you to enter your private keys or wallet seed. YOU ARE SOLELY RESPONSIBLE FOR KEEPING YOUR WALLET PASSWORD, PRIVATE KEYS, AND SECRET RECOVERY/BACKUP PHRASE SAFE AND CONFIDENTIAL.
Information Automatically Collected. We may collect certain data automatically. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding its features and functionality and tailoring it to our users’ needs and preferences.
Information we collect from you automatically may include:
4. USE OF PERSONAL INFORMATION
To provide our service
We may use your personal information in the following ways:
To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
To communicate with you
We may use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety
Other Legitimate Interest
We may use your information for other legitimate purposes in order to provide the Services. We may use your information to fulfill our contractual obligations pursuant to the terms of such applicable contract when it is reasonably necessary to achieve our legitimate business interests.
5. SHARING OF PERSONAL INFORMATION
Anonymized and Aggregated Data
We may also share aggregated and/or anonymized data with others for their own uses. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely for any business purpose without further notice to you. Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.
6. HOW INFORMATION IS SECURED
We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
7. INFORMATION CHOICES AND CHANGES
Where appropriate or legally required, we will describe how we may use the information collected about you so that you can make choices about how your information is used. Further, depending where you are located, you may have certain rights in connection with the personal information that we obtain about you. These rights vary depending on your jurisdiction and are generally described with regards to certain individuals in Sections 9, 10 and 11 below.
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to email@example.com. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
Please note that, by design, blockchain data is publicly available and may not be capable of being changed or deleted due to its immutable nature. This may affect your ability to exercise certain rights that may otherwise be available to you (such as the right to erasure, to object, or to restrict processing of your personal data). Although smart contracts may be used to revoke certain access rights and some content may be made invisible to others, it is not deleted.
Tracking Technologies Generally
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.
9. NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code Section 1789.3, California users of the Site are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
This section provides additional details about the personal information we may collect about California consumers and the rights they may have under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Harbor Labs does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please refer to our Cookies Policy for more information regarding the types of third-party cookies, if any, that we use.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information collected about them (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
10. NOTICE TO CERTAIN EUROPEAN DATA SUBJECTS
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
Legal Bases for Processing
We only use your personal information as permitted by law. Below are the legal bases of any processing of your personal information. If you have questions about the legal bases under which we process your personal information, contact us at email@example.com.
|Processing Purpose||Legal Basis|
|To provide our service||Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.|
|To communicate with youTo optimize our platformFor compliance, fraud prevention, and safetyTo provide our service||These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||We use your personal information to comply with applicable laws and our legal obligations.|
|With your consent||Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Services or by contacting us at firstname.lastname@example.org.|
Use for New Purposes
In some regions like the EEA and UK, you may have certain rights regarding your personal information under applicable data protection laws. If applicable, you may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to email@example.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at firstname.lastname@example.org or submit a complaint to the data protection regulator in your jurisdiction. If you are a resident of the EEA or UK, you can find a list of data protection regulators in Europe here. If you are a resident of Switzerland, the contact details for the data protection authorities are available here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
11. NOTICE TO VERMONT RESIDENTS
The Vermont Financial Privacy Act limits what we can do with your financial information and gives you rights to limit our sharing of your financial information. Under the Vermont Financial Privacy Act, Vermont residents have the right to receive notice and opt-in to sharing non-public Personal Information with non-affiliated third parties. Additionally, residents must consent to us sharing information regarding credit worthiness.
13. CONTACT INFORMATION
We welcome your comments or questions about this Policy, and you may contact us at: email@example.com.