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Privacy Policy
HATS.FINANCE PRIVACY POLICY
Last Updated: August 30, 2021
This privacy policy (“Privacy Policy”) governs how we, Incentive Alignment Ltd. (together, “Hats Finance” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“you”) such as in the use cases mentioned in section 1.
Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. SOME OF YOUR DATA WILL BE STORED ON A BLOCKCHAIN-BASED NETWORK (ETHEREUM BLOCKCHAIN) AND, THEREFORE, WILL BE ACCESSIBLE TO ANYONE. IF YOU DISAGREE WITH THIS, PLEASE DO NOT USE OUR PRODUCTS AND SERVICES.
Table of contents:
  1. 1.
    What information we collect, why we collect it, and how it is used
  2. 2.
    How we protect and retain your Personal Data
  3. 3.
    How we share your Personal Data
  4. 4.
    Your privacy rights
  5. 5.
    Use by children
  6. 6.
    Interaction with third party products
  7. 7.
    Log files
  8. 8.
    Analytic tools
  9. 9.
    Specific provisions applicable under California privacy law
  10. 10.
    Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
  1. 1.
    WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
  2. 2.
    We Process the following Personal Information:
  3. 3.
    Information You Provide Directly to Us. We collect Personal Data you provide directly to us, including Personal Data when you browse and make use of our website https://hats.finance/ (“Website”) and/or our application Https://app.hats.finance (“Application”), including, full name, email address, and other information that you decide to share with us. When you communicate with Hats Finance (via email, website or telephone), we collect the contents of those communications, as well as feedback, and/or answers to surveys or questionnaires that you may submit.
  4. 4.
    Information provided in the context of Hats Finance Application: Hats Finance may receive information in the context of providing its services to you. [Shay – please confirm or amend as necessary the below descriptions]
    1. 1.
      When you are a member of a committee in our Application (“Committee”), we collect your full name,, twitter user, public key, telegram user, picture and other information that you make available to us.
    2. 2.
      When you are a governance member, depositors and/or investors, we collect your full name, email address, phone number, log-in details picture and other information that you make available to us
    3. 3.
      When you are a white hacker, we collect your wallet information, transaction information, Telegram user details and any other information that you decide to send us.
For the avoidance of doubt, the Telegram user details and any messages (vulnerabilities found) that you decide to provide the committee is encrypted and only the relevant Telegram committee can access and decrypt such messages.
  1. 1.
    Information from Other Sources. Hats Finance may also obtain information (that in general will not contain Personal Data) about you from other sources, including private and publicly - or commercially - available information, and through third-party partners and service providers. [Shay – please confirm if this is relevant]
  2. 2.
    Automatic Data Collection. We may automatically collect certain information through your use of the Hats Finance Website and Application, such as cookie identifiers and other device identifiers, analytic tools and log files that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Hats Finance services.
  3. 3.
    We Process Personal Information for the following purposes:
  4. 4.
    To provide you with the Hats Finance Application. Hats Finance will use your information to provide the Hats Finance Application, including: (i) to process your vulnerability submission; (ii) to share your message and vulnerability submission with the relevant Committee; (iii) to communicate with you about the vulnerability request in case that the Committee has any question; (iv) track the vulnerability request sent by you; (vi) to allow you to connect your wallet; (v) to create and publish the relevant information of the Committee members; (vii) to create and publish the relevant information of the governance members; (viii) to provide you with a user friendly interface to Hats smart contracts; (ix) to provide you with information about our Application and its capabilities; and (x) to personalize your experience with the Hats Finance Application. [Shay – please confirm or amend as necessary the below descriptions]
  5. 5.
    For Administrative Purposes. Hats Finance may use your information (i) to respond to your questions, comments, and other requests for support, or information; (ii) to provide you with the Hats Finance Application and services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) for testing, research, analysis, and product development, including to develop and improve our Website and Application, and in connection with providing and maintaining our products, and services; and (vi) to generally administer the Hats Finance Website and Application. [Shay – please confirm or amend as necessary the below descriptions]
  6. 6.
    To Market the Hats Finance Application. Hats Finance may use information to market the Hats Finance Website and Application. Such use includes (i) notifying you about offers and services that may be of interest to you that we offer and/or that we offer jointly with or on behalf of other organizations; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Hats Finance’s services; (v) other purposes disclosed at the time you provide Personal Information; and (vi) as you otherwise consent. [Shay – please confirm or amend as necessary the below descriptions]
  7. 7.
    Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
  8. 8.
    De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
  9. 9.
    Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Hats Finance Website, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Hats Finance Website. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Hats Finance Website. If you would like to opt out of the Technologies we employ on the Hats Finance Application, you may do so by blocking, deleting, or disabling them as your browser or device permits.
Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
  1. 1.
    HOW WE PROTECT AND RETAIN YOUR INFORMATION
    1. 1.
      Data stored by Hats Finance: The data stored by Hats Finance will, in order to ensure the functioning of the services and Website.
    2. 2.
      Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
    3. 3.
      Retention of your Personal Data. Your information will be stored until we delete the record and we proactively delete it or you send a valid deletion request. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy.
    4. 4.
      Data stored on the blockchain: The data stored on the Ethereum Blockchain will be stored perpetually, without any way for deletion, Ethereum network which is a decentralized and open-source network. Please note that, given the nature of the blockchain, the effectiveness of the security measures depends on the efforts of a decentralized network of miners, validator nodes and proof-of-stake participants, among other participants in the Ethereum Network. In any event, as an additional precaution, we have followed a data minimization approach to ensure that little personal data is processed (as further described in Section 1 above). Therefore, in the event of a data breach or security incident, such incident is unlikely to result in a risk to your rights and freedoms because the amount and nature of the personal data potentially compromised is not sensitive and is unlikely to reveal any private aspect or cause you any damage.
    5. 5.
      IF YOU DISAGREE WITH THIS SECTION 2, PLEASE DO NOT USE OUR SERVICES AND WEBSITE.
  2. 2.
    HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal Data as follows:
    1. 1.
      Data stored by Hats Finance:
    2. 2.
      With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
    3. 3.
      We may use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation:
      1. 1.
        With cloud service providers for hosting purposes;
      2. 2.
        With word press service providers in order to help us manage our Website and Application;
      3. 3.
        With email providers, marketing, CRM and other similar tool providers; and
      4. 4.
        With analytic companies, in order to help us understand and analyze data we collect in accordance with this policy.
      5. 5.
        [Shay – please add more categories that may be missing]
    4. 4.
      To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
    5. 5.
      If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
    6. 6.
      In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
    7. 7.
      Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
    8. 8.
      Data stored on the blockchain: The information stored on the Ethereum Blockchain Network will be shared with anyone accessing the Ethereum Blockchain Network, since the Ethereum Blockchain Network is a decentralized and public protocol, which could include parties that are located outside from your country or jurisdiction. Please note these parties may be located in countries and jurisdictions that do not approach or protect your privacy rights as in your jurisdiction. In any event, please note that sharing data with such parties is necessary for providing the services at hand. Moreover, please note that given the implementation of our data minimization approach, the only information that will be shared is described in Section 1.
    9. 9.
      IF YOU DISAGREE WITH THIS SECTION 3, PLEASE DO NOT USE OUR APP.
  1. 1.
    YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
    1. 1.
      Data stored by Hats Finance: Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
  • You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
    1. 1.
      You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
    2. 2.
      Data stored on the blockchain: IMPORTANT NOTE: SOME OF THE ABOVEMENTIONED RIGHTS CANNOT BE HONORED IN CONNECTION WITH THE DATA STORED ON THE BLOCKCHAIN. GIVEN THE NATURE OF THE BLOCKCHAIN, THE DATA IDENTIFIED IN THE TABLE IN SECTION 1 AS “STORED ON THE BLOCKCHAIN” WILL REMAIN STORED ON THE ETHEREUMBLOCKCHAIN NETWORK AND WILL REMAIN ACCESSIBLE TO ANYONE.
    3. 3.
      IF YOU DISAGREE WITH THIS SECTION 4, PLEASE DO NOT USE OUR APP. We and our services do not perform any processing activity for the purposes of making automated decisions or profile you in any manner.
  1. 1.
    USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. We do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
  2. 2.
    INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
  3. 3.
    LOG FILES. We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
  4. 4.
    ANALYTIC TOOLS
  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
We reserve the right to remove or add new analytic tools.
  1. 1.
    CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].
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